Finding Text
Finding 2022-002: Internal control deficiency and noncompliance over Eligibility. Information of the federal program: Assistance Listing Number 93.914: ? HIV Emergency Relief Project Grants ? U.S. Department of Health and Human Services ? Federal award identification number ? Not available ? Federal award year: o March 1, 2021 to February 28, 2022 o March 1, 2022 to February 28, 2023 ? Pass-through entity ? City of Newark Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 ? Internal controls. The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The grant agreement of the award requires the following: ? Re-certification is required six months after certification and must include verification of income and household size < 500% of federal poverty level, residency, and health insurance status. Changes in status must be documented. Condition: During our testing of eligibility, we observed management did not have effective internal controls in place to ensure patients were checked for eligibility every six months and retain supporting documentation to support income verification. This resulted in the entity being out of compliance of the program requirements outlined in the grant agreement. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or potential effect: Patients receiving services from this grant could potentially be ineligible to be in the program. Questioned costs: Questioned costs for Assistance Listing Number 93.914 ? HIV Emergency Relief Project Grants are indeterminable, as program expenditures are not made on a per participant basis. Context: During our testing over eligibility, we obtained a listing of 1,785 patient visits and selected a sample of 65. We found the following: ? There were 15 out of 65 selections where the patient was not checked for eligibility every six months. ? There were 3 out of 65 selections where the entity did not have supporting documentation to support income verification. Identification as a repeat finding, if applicable: No. Recommendation: Management should develop and implement effective internal controls to ensure patients are checked for eligibility every six months and retain supporting documentation to support income verification. Views of responsible officials: Clinic management team acknowledges that from the audit selection made of 65 patients that 15 were not recertified during the six-month period and the supporting documentation was not retained related to income verification for 3 patients. A detail plan of correction has been developed and is listed below: ? Revamping the job titles and description to encourage better return on recruitment efforts of medical case managers position. ? A position of Certified Case Counselor (CCC) ? Supervisor, was created and filled to provide direct oversight over the medical case managers that perform the bi-annual certifications, and other daily tasks. ? Quality management process, where Clinic clients are called ahead of time to notify them of their recertification requirements. ? Data Analyst(s) will generate a report of patients due for recertification 60 days in advance of the due date. The CCC-Supervisor will be directly accountable to review the progress of the re-certification. This will be further monitored by the Assistant Manager of the clinic. The CCC-Supervisor and Assistant Manager will also monitor retention of income verification supporting documentation for patients.