Finding 504714 (2023-001)

Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health Pass-Through Entity Number: INORWB611-GY22; INORPS611-FY23; INORWB611-GY23 Awards: Assistance Listing Number 93.917 – HIV Emergency Relief Project Grants (Part B) Award Periods: April 1, 2022 to March 31, 2023; July 1, 2022 to March 31, 2023; April 1, 2023 to March 31, 2024 Description: Timely Completion of the 24-month Eligibility Screening Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Per the terms and conditions of the pass-through entity agreement between the Virginia Department of Health (the Department) and the Inova Juniper Program (IJP), IJP is required to “conduct and complete a full RWHAP B eligibility screening for all clients for any allowable Ryan White services prior to enrollment in the RWHAP B program and every 24-months thereafter by following the procedure from the department” (INORWB611-GY22 – Scope of Services – Section E, INORPS611-FY23 – Scope of Services – Section A, INORWB611-GY23 – Scope of Services – Section G1). The procedure from the department of the award requires the recipient to resubmit documents for residency, household income and proof of insurance before the 24-month eligibility period ends. Condition The System did not have appropriately designed internal controls in place to ensure that the documentation is obtained and reviewed to verify eligibility prior to the end of the 24-month period. Cause IJP has policies and procedures in place to obtain the eligibility documents from all clients and retain in their files. IJP’s policies and procedures specify that an eligibility worker will meet with each client for an initial screening to verify residency, income, insurance status, and HIV status. The eligibility worker is required to meet with the client to update the required eligibility screening and include the required documentation in the client file by the 24-month period end. Additionally, at each subsequent visit, the receptionist questions each client as to whether there have been any changes in their income or insurance status. If there are changes to the client’s eligibility status, another visit is scheduled with the eligibility worker. If there are delays with responses from the clients, the required documentation may not be obtained by the 24-month period end. Effect or potential effect Eligibility workers did not obtain and/or retain the required documentation related to the 24-month eligibility screening for certain clients before the required date. Based on the terms and conditions of the pass-through agreement with the Department, the clients whose eligibility was not completed by the deadline would not be considered eligible and should be discharged from the program. Questioned costs None. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2022-002. Context During our audit, we selected a sample of 60 clients for testing and noted the following exceptions: • The 24-month eligibility screening was submitted to the Department after the eligibility expiration date for one client. For the exception identified, services were not provided prior to obtaining the full eligibility screening and therefore, there were no unallowable costs identified required for reimbursement from the Department. IJP has not completed a full review of all clients that could be impacted by the exception above. Recommendation Management should implement procedures to ensure completion of the eligibility screening prior to the end of the 24-month eligibility period. View of responsible officials Management concurs with the finding and will implement procedures to ensure that timely documentation is received with regard to eligibility.