Finding Text
CRITERIA Federal regulations and the terms of the HIV Emergency Relief Project Grants (Ryan White Part A program) require that grantees collect and retain sufficient documentation to support the eligibility of all clients served, including proof of HIV-positive status and low-income status. Only services to eligible clients may be charged to the federal award. CONDITION AND CONTEXT During our review of client eligibility under the Ryan White Part A program, we identified instances where services were incorrectly charged to the program for clients who did not meet federal eligibility requirements. Specifically, mental health assessment services for six clients (totaling 29 services) were charged to the Ryan White Part A program, but these services were related to a different federal award. For one client reviewed in detail, the file did not contain adequate documentation of HIV-positive status, as required, nor documentation of low-income status. The lab results for 2023 noted a negative HIV test, and management’s alternative method for determining eligibility (using “undetectable” ranges from other tests) was not supported by guidance from DC Health or federal agencies. In addition, required eligibility data was not collected or retained in accordance with federal regulations. CAUSE Management relied on local reporting requirements rather than federal regulations and did not implement internal procedures to ensure that eligibility documentation was collected and retained for federal audit purposes. EFFECT OR POTENTIAL EFFECT Charging services for ineligible clients or clients without required documentation to a federal award may result in questioned costs, disallowed costs, noncompliance with federal regulations, and potential repayment of federal funds. Failure to collect and retain proper eligibility documentation undermines the integrity of UHU’s compliance with federal requirements. RECOMMENDATION We recommend that management establish and enforce procedures to ensure that eligibility documentation – including proof of HIV-positive status and low-income status – is collected and retained for all clients served under federal programs. In addition, management should ensure that only services provided to eligible clients are charged to the appropriate federal award, in accordance with federal regulations. Staff should be trained on these requirements, and regular reviews should be conducted to ensure compliance.