Finding Text
Criteria- According to 2 CFR 200.303, non-federal entities receiving federal awards must establish and
maintain internal controls that comply with the guidance in COSO’s "Internal Control Integrated Framework.” This regulation requires management to design control activities to achieve compliance objectives and respond to compliance risks. Additionally, specific program requirements mandate that eligibility determinations must be supported by adequate documentation. This includes verifying that individuals meet all eligibility criteria, such as proof of HIV diagnosis, income status and residency, before granting benefits.
Condition-During the testing of eligibility, multiple issues were noted with proper approval and maintaining proper eligibility information within the client files. Specifically, three individuals lacked the proper support in their files to determine eligibility. Additionally, there were three applications that did not include proof of review prior to the notice of eligibility being granted.
Cause - The primary cause of the errors identified was lack of administrative oversight and a lack of effective control activities such as effective review procedures and monitoring.
Effect - The Organization granted notices of eligibility to individuals without the required supporting documentation and/or proper approval.
Questioned Costs - Not applicable
Context - Prior to a notice of eligibility (NOE) being granted, it must be verified that the individual has valid proof of HIV diagnosis, be considered low income, and be a resident of the state in which they are applying in. Eligibility documentation should be retained in the client file. Out of the sample of 40 client files tested, we noted three individuals who did not have all requirements within their file. Two individuals did not have proof of HIV, and one individual did not have valid proof of residency. OASIS Florida was able to obtain the proof of HIV from the health department for both individuals in question, but the individual without proof of valid residency was determined to not be a resident of Florida and incorrectly received an NOE. After an eligibility application is completed, it is given to a case manager for review. Prior to eligibility being granted, the case manager is supposed to sign that they have reviewed the eligibility application. Out of the sample of 40 files tested, three applications did not include proof of review prior to the notice of eligibility being granted.
Recommendation - We recommend the client implement controls to ensure all eligibility documentation is obtained and properly reviewed before granting eligibility. This includes providing regular staff training and conducting periodic internal audits to ensure compliance.
Views of Responsible Officials - We agree with the recommendation offered.