Finding Text
Type of Finding: Significant Deficiency
Federal program information:
Funding agency: U.S. Department of Health and Human Services
Title: Urban Indian Health Centers
Assistance listing number: 93.193
Criteria: Proper internal controls over eligibility requirements that govern Native American Organizations should involve documentation that patients receiving services were eligible Urban Indians residing in the urban centers in which the organization is located.
Condition: Controls currently in place to ensure that all eligibility requirements are met are not adequate. As a result, for two of twenty-five individuals selected for testing who received services through the Urban Indian Health Centers program, the Center was initially unable to provide sufficient evidence to justify that the participants were eligible to receive services. Documentation was obtained after patients were sampled as a result of Single Audit testwork.
Questioned Costs: N/A
Context: Evidence of Tribal affiliation was not initially retained; however, management was familiar with patients and was able to obtain the required documentation after patients were sampled for eligibility testwork as part of the Single Audit.
Cause: Program management has not designed a proper system of documentation to ensure that patients serviced meet program eligibility requirements and are properly supported as required by OMB Uniform Guidance. Center personnel may be familiar with patients and their Tribal affiliation in tight-knit community and are not diligent about requesting and retaining evidence of Tribal eligibility.
Effect: Providing services to potentially unqualified applicants may result in lack of funding from the federal government.
Auditor’s Recommendations: Program management should design and implement an internal control system that adequately documents patient eligibility to ensure that patients and applicants are eligible.
Management’s Response: Hunter Health has revised its Native American Beneficiary Program Policy (CH-004) and corresponding procedure to correct this finding. In March of 2024 the revised policy was approved by Hunter’s Policy Review Team. This policy defines eligibility for the Native American Beneficiary Program, its scope of services, and outlines the documentation required. The correlating procedure, “Enrolling Native American Beneficiaries” goes further into detail with regards to eligibility and what specific documentation is collected.
Specifically, Hunter Health has removed the requirement that a birth certificate be provided when a child is under 18 to prove that they belong to the Native American parent/guardian. Instead, as stated in the revised procedure, and in addition to the document requirements of the parent/guardian, Hunter now accepts “an attestation form signed by an eligible beneficiary parent/stepparent/legal guardian of a minor declaring the relationship and the minor’s eligibility for benefits.”
An additional update to the policy has been made to allow a Native American father of a non-native American pregnant woman to attest in writing that he is the father of the Native American child and is not required to provide a marriage certificate.