Finding 1115287 (2024-002)

Finding 2024-002: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Health and Human Services (HHS) State Awarding Agency: Virginia Department of Social Services (VDSS) Program Name: Medicaid Cluster ALN: 93.778 Compliance Requirement: Eligibility Prior Year Audit Finding Number: N/A Criteria: Per Title 2 Subpart §200.303, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.” Per Subchapter M1520.001 of the Virginia Medical Assistance Eligibility Manual, “An annual review of all of the enrollee's eligibility requirements is called a ‘redetermination’ or ‘renewal’.” A renewal of the enrollee's eligibility must be completed at least once every twelve (12) months. An enrollee whose eligibility redetermination was due during the COVID-19 public health emergency (the “PHE”), which was declared on March 13, 2020 and expired May 11, 2023, was automatically reenrolled. At the end of the PHE, the Virginia Department of Medical Assistance Services published a renewal calendar which provided for renewals that were originally due during the PHE to be completed over the period April 2023 through February 2024. Per Subchapter M0240.001 of the Virginia Medical Assistance Eligibility Manual, “To be eligible for medical assistance (MA), an individual must provide his Social Security number (SSN) as well as the SSN for any person for whom MA is requested, or must provide proof of application for an SSN.” Condition: During our testing of sixty (60) beneficiaries that were enrolled in the Medical Assistance Program, we noted thirteen (13) beneficiaries continued to receive medical assistance when an eligibility redetermination was not performed within twelve (12) months of the prior eligibility determination or the extended timeline prescribed by the Virginia Department of Medical Assistance Services as a result of the PHE. For eleven (11) of these thirteen (13) instances, the redeterminations were performed late with beneficiaries found to have been eligible. For two (2) of the thirteen (13) instances, documentation requested from the beneficiaries to perform the redetermination was not provided and the beneficiaries’ eligibility was ultimately terminated. Additionally, we noted two (2) instances in which beneficiaries’ eligibility determination did not include the Social Security number for a child of the beneficiary receiving medical assistance. Cause: The County does not appear to have adequate policies and procedures in place to ensure a consistent and systematic review of the beneficiary case files. Effect: The Medical Assistance Program as operated by the County was not in compliance with the eligibility compliance requirement as of June 30, 2024. Additionally, failure to timely perform renewals could result in medical assistance rendered to ineligible individuals. Recommendation: The County should implement a plan to enhance internal controls related to participant eligibility to ensure renewals are occurring on a timely basis and files contain adequate supporting documentation in accordance with the Uniform Guidance. Questioned costs: Not determinable. Context: This is a condition based on testing of the County’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a nonstatistical method. Views of Responsible Officials: The County concurs with the auditor’s finding and recommendation.