Finding 385492 (2023-001)

Criteria: Program income for the Ryan White programs lacked controls. Program income was not being allocated or tracked separately amongst the Ryan White C and D programs. Condition and Context: All charges generated from the Ryan White programs were going to one fund instead of being separated for each Ryan White program. The 340B revenue was not allocated to Ryan White C. Effect: If the program income is not allocated to the respective Ryan White programs, the related earnings may not be used for respective program expenses. Cause: Program income controls and process were not implemented and routinely performed. Recommendation: Appropriate internal controls over the Ryan White program income should be established and documented. A new fund for each Ryan White program should be maintained to properly track program income within the fund. The 340B revenue should go to the Ryan White C fund. Current Year Status: While management has made multiple improvements to the program income processes, patient payments included in program income for the Ryan White programs lacked control over the allocation of the payments and a finding was issued in the current year. A new fund was established for Ryan White programs, and expenses were tracked through the new funds. All of the 340B revenue was properly allocated to Ryan White C fund.