Finding 3773 (2023-001)

2023-001 Eligibility Federal Grantor: Department of Health and Human Services, Health Resources and Services Administration (“HRSA”) Pass-through Entity: City of Philadelphia, AIDS Activity Coordinating Office (“AACO”) Assistance Listing Title: HIV Emergency Relief Project Grants – Outpatient/Ambulatory Medical Care Assistance Listing Number: 93.914 Award Year: 2023 Award Number: RW2965 Pass-through Number: 2120575-01 Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, “The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.” Additionally, the form states that copy of all documentation are to be retained by the provider. The City of Philadelphia Subrecipient Audit Guide Section 6130.04 provides a list of documents to be maintained and states “case management service providers are required to keep a file on each client served.” Further, per the Universal Monitoring Standards set forth by HRSA, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents. Condition We reviewed a sample of 65 program participants to verify eligibility during the fiscal year. Of the 65 selected, there were 6 program participants at the Wood Clinic within the Clinical Care Associates of the University of Pennsylvania Health System (“Health System”) in which the Health System did not maintain Ryan White certification cards as documentation evidencing the control in place to certify the verification of the program participant’s eligibility. However, for all 6 program participants, the Health System provided records to support that the program participant met the eligibility requirements. Cause Management of the Health System noted that the AACO program at the Wood Clinic ended in November 2022 and the individuals involved in the process did not maintain the documentation evidencing that management verified participant eligibility in the program. Effect Program participants accepted into the program may be ineligible and the Health System may not be able to demonstrate eligibility of the participants. Questioned Costs None Recommendation The Health System should ensure that all individuals involved in the Ryan White certification process are educated that documentation is required to be maintained to support verification of program participant eligibility. Management’s View and Corrective Action Plan Management’s view and corrective action plan is included at the end of this report.