Finding 1155366 (2024-001)

Reference Number: 2024-001 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.778 Pass-Through Entity: New York State Department of Health Identifying Number and Period: DOH01-C37308GG-3450000 (7/1/2022 – 6/30/2027) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: The financial and nonfinancial factors of eligibility must be verified per federal requirements at 42 CFR 435.948 through 435.956 and state requirements (as documented in the state plan, verification plan, and eligibility manual). The County must ensure that only eligible participants receive services under the program. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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 comply 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). Condition: The County did not maintain adequate documentation of program participant eligibility, nor did it ensure that non-long-term care program participants were properly classified. Context: Sixty participants were selected for testing and the following exceptions were noted: • For five of sixty participants selected for testing, the County was unable to provide documentation that a program supervisor had approved the application. • For one of sixty participants selected for testing, the County was unable to provide a signed participant application. • For one of sixty participants selected for testing, upon reapplication and further documentation, a long-term care case was determined to be non-long-term care, but the County did not make this change and the participant was misclassified. Cause: The County’s procedures were not sufficient to ensure it properly classified program participants nor that eligibility documentation of program participant eligibility was maintained. Effect: Services may have been provided to an ineligible participant. Questioned costs: Undetermined. Recommendation: The County should enhance its procedures and internal controls to ensure it maintains documentation of participant eligibility. It should also enhance procedures and internal controls to ensure participants are correctly classified as long-term care versus non-long-term care. Views of Responsible Officials: There is no disagreement with the audit finding.