Finding 1151511 (2024-001)

Finding 2024-001 Internal control deficiency and noncompliance over Eligibility. Identification of the federal program: Assistance Listing Number 93.914: • HIV Emergency Relief Project Grants • U.S. Department of Health and Human Services • Federal award identification number – Not available • Federal award year – March 1, 2022 to February 28, 2025 • Pass-through entity – City of Newark Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 Internal controls. 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). The grant agreement of the award requires the following: • Re-certification is required six months after certification and must include verification of income and household size < 500% of federal poverty level, residency, and health insurance status. Changes in status must be documented. • Clients must be certified upon determination of eligibility, and every 12 months thereafter, by documentation of HIV/AIDS status (new clients only), income, household size, residency, and health insurance status. Condition: During our testing of eligibility, we observed management did not have effective internal controls in place to ensure patients were checked for eligibility every six months, annually, and retain supporting documentation to support household size and residency. This resulted in the Clinic being out of compliance with the program requirements outlined in the grant agreement. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or potential effect: Patients receiving services from this grant could potentially be ineligible to be in the program. Questioned costs: Questioned costs for Assistance Listing Number 93.914 – HIV Emergency Relief Project Grants are indeterminable. Context: During our testing over eligibility, we obtained a listing of 1,628 patients and selected a sample of 60. The sampling was a statistically valid sample. We found the following: • There were 9 out of 60 selections where the patient was not checked for eligibility every six months. • There was 1 out of 60 selections where the patient was not checked for eligibility annually. • There was 1 out of 60 selections where the Clinic did not have supporting documentation to support household size. • There were 3 out of 60 selections where the Clinic did not have supporting documentation to support residency. Identification as a repeat finding, if applicable: Yes – 2023-001 Recommendation: Management should develop and implement effective internal controls to ensure patients are checked for eligibility every six months, annually, and retain supporting documentation to support household size and residency. Views of responsible officials: Clinic management team acknowledges that from the audit selection made of 60 patients, 14 were not recertified during the six-month period and the supporting documentation was not always obtained or retained related to income verification, household size, residency, and health insurance status. The corrective action plan as developed for CY 2023 will be continued to be reinforced and followed. The plan did result in lower findings than in prior years. A new bullet was added in the fourth quarter of 2024 to further assist in meeting the compliance guidance. The addition is the last bullet listed below. • Revamped the job titles and description to encourage better return on recruitment efforts of medical case manager positions. • A position of Certified Case Counselor (CCC) – Lead, was created and filled to provide direct oversight over the medical case managers that perform the bi-annual certifications, and other daily tasks. • Added a quality management process, where Clinic clients are called ahead of time to notify them of their recertification requirements. • Data Analyst(s) generate a report of patients due for recertification 60 days in advance of the due date. The CCC-Lead is directly accountable to review the progress of the re-certification, and the process is monitored by the Assistant Manager of the clinic. The CCC-Lead and Assistant Manager monitor retention of all patients required supporting documentation in the patients’ medical records. • Patients that do not provide the required supporting documentation showing compliance with program eligibility as outlined in the grant agreement or are otherwise not able to be recertified six months after certification will be classified as inactive in the database used to submit invoices to the Ryan White HIV/AIDS Program. • CCC-Lead has been assigned to preview charts on the daily appointment book in EPIC and sending a list of the documentation required via email to case management staff as they meet with the patients.