Hawaii Health & Harm Reduction Center

HHHRC is committed to continuing to improve its adherence with established policies and procedures to verify eligibility documentation for recipients of Ryan White Part B Program funds. HHHRC will review these findings with all relevant staff and provide a refresher training on appropriate documentation of eligibility (with a focus on income determination and reference dates as described in the condition section) by the end of March 2026. HHHRC will review its current internal controls process which currently includes review from the HIV Program Manager and random quality assurance checks from the Quality Program Coordinator. The HIV Director and/or the Deputy Director of Community Programs will be responsible for reviewing, updating, and implementing any changes to HHHRC internal auditing to ensure program compliance. HHHRC understands that this is a repeat finding and continue to prioritize both staff training and refinement of our internal review process to ensure compliance.

2024-001

Refer to “Views of Responsible Officials and Planned Corrective Action” for Finding No. 2025-001.

2024-001

HHHRC agrees that policies and procedures must be followed so that only allowable costs with clients documented to be eligible are processed. HHHRC is working with the State to determine the best process for ensuring there were no other billings for ineligible clients. HHHRC will be instituting a fiscal review to ensure any errors are caught prior to processing billings.

HHHRC fiscal staff will print out and retain a copy of the supervisor’s review and approval of employees funded by RWB program time and attendance each pay period.

We provided staff training on this new policy and continue to monitor its implementation to ensure full compliance. This measure will help maintain the integrity of our data and ensure that all necessary sign-offs are obtained prior to database entry.

2023-001

HHHRC is continuing to implement its planned corrective action plan noted in the Current Status sections of the prior audit findings. To ensure further compliance, HHHRC hired a Case Management Assistant (CMA) in August 2023. The CMA’s responsibility includes reviewing client files to ensure required documentation and certifications are present in the files and completed accurately. Additionally, the HIV leadership team has created a primary spreadsheet of all client’s receiving services and has assigned the monitoring of the spreadsheet to the CMA. This primary spreadsheet will assist the HIV team with tracking the receipt of documents, upcoming or expired certifications, and assist with document retrieval. The updated policies, improved training, along with the added support of the Quality Program Coordinator and Case Management Assistant should shore up gaps in the certification process.

2022-001

HHHRC is continuing to implement its planned corrective action plan noted in the Current Status sections of the prior audit findings. To ensure further compliance, HHHRC hired a Case Management Assistant (CMA) in August 2023. The CMA’s responsibility includes reviewing client files to ensure required documentation and certifications are present in the files and completed accurately. Additionally, the HIV leadership team has created a primary spreadsheet of all client’s receiving services and has assigned the monitoring of the spreadsheet to the CMA. This primary spreadsheet will assist the HIV team with tracking the receipt of documents, upcoming or expired certifications, and assist with document retrieval. The updated policies, improved training, along with the added support of the Quality Program Coordinator and Case Management Assistant should shore up gaps in the certification process.

2022-002

US Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, HI 96813 Hawaii Health & Harm Reduction Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30, 2022 for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY LLC, who are located at Topa Financial Center, 745 Fort Street, Suite 2100, Honolulu HI 96813 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1, 2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy. Views of Responsible Officials and Planned Corrective Action HHHRC has implemented a formal policy and review process by a manager or higher level within the organization for every certification form within 1 week of completing the form. As noted earlier in the audit, HHHRC has made significant progress on this compliance measure with certifications dated after April 1, 2022 having significantly higher review rates (26/32 had review compared to 2/60 prior to April 1, 2022). Additionally, HHHRC has added an additional policy of the HIV Director or Clinical Deputy Director will review twice annually a random selection of at least 20 certification forms to ensure there was manager review documentation and this internal control will hopefully identify any deficiencies in this practice.

2021-001

Significant Deficiency Finding 2022-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: ? For 16 of the 60 clients selected, the file contained insufficient documentation to verify that the payer of last resort requirement was met. ? For three of the 60 client files selected, the file did not have annual or semi-annual certification forms dated prior to certain dates of services, indicating that eligibility determinations were not performed prior to billing the Ryan White program. ? For one of the 60 client files selected, the file contained certification forms that were more than 6 months apart. During that gap in certifications, services for the client were billed. ? For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Per HHHRC?s Ryan White Eligibility Policy, these eligibility criteria are to be documented in their Annual Certification forms, and their Six-Month Semi-Annual Certification forms. HIV status must be documented by a written statement from a medical provider. Lab results may only be used on an interim basis. Residency must be documented with a State ID card or a driver?s license, lease agreement, utility bill, official government mail, bank statement, pay stub, or a verification letter from an agency providing the client with housing. Income levels must be documented with the most recent pay stubs covering 30 consecutive days, benefit statements, IRS tax transcripts, or a signed statement from the client attesting to no income or very low income. For the payer of last resort criteria, HHHRC?s policy states that they must, at a minimum, assess and re-assess the client?s eligibility for benefits such as MedQuest. In addition, HHHRC must make reasonable efforts to secure funding, besides the Ryan White program, including pursuing enrollment into health care coverage. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2022-001, HHHRC updated their formal policies and procedures effective April 1, 2022 to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs No questioned or known costs were identified. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-002. Recommendation We again recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider expanding on their policies for payer of last resort, with more specific criteria for documentation required to support compliance with this requirement. Views of Responsible Officials and Planned Corrective Action HHHRC has implemented a formal policy and review process by a manager or higher level within the organization for every certification form within 1 week of completing the form, as noted above. This policy and process also compares the certification and/or reassessment forms against the comprehensive client list so managers will review monthly and be able to identify any clients that need re-certifications in addition to new certifications. Additionally, HHHRC has added an additional policy of the HIV Director or Clinical Deputy Director will review twice annually a random selection of at least 20 certification forms to ensure there was manager review documentation and this internal control will hopefully identify any deficiencies in this practice and this will identify if the managers are missing anything in the initial review. For documentation of payor of last resort, HHHRC has implemented a more rigorous policy on documentation of utilizing Ryan While as payor of last resort and one of the main methods for ensuring compliance is a new Billing Specialist position which started last year and is reviewing all expenses associated with this program and ensuring compliance of payor of last resort as well as ensuring appropriateness of cost.

2021-002

US Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, HI 96813 Hawaii Health & Harm Reduction Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30, 2021 for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY LLC, who are located at Topa Financial Center, 745 Fort Street, Suite 2100, Honolulu HI 96813 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2021-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. For 57 out of the 60 samples selected, we noted that the eligibility determination performed by the case manager was not reviewed by an individual other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by knowledgeable supervisors. Cause HHHRC does not have formal policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process for the RWB program are reviewed by knowledgeable supervisors. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2021-002 for instances of noncompliance identified in the current year. Recommendation We recommend that HHHRC establish and adhere to formal policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process for the RWB program are reviewed by knowledgeable supervisors. Views of Responsible Officials and Planned Corrective Action HHHRC has integrated the recommendation of all new and re-certified participants of the RWB program will be reviewed by management to ensure that all eligibility documentation is appropriate and demonstrates eligibility for the RWB program. This policy has been integrated into HHHRC?s RWB manual and managers have been trained and developed workflow to implement and adhere to this practice.

Significant Deficiency Finding 2021-002 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 60 clients receiving assistance under the RWB program to ascertain whether those clients met the RWB program eligibility requirements. We noted that documentation supporting compliance with eligibility requirements for certain clients were incorrect, incomplete, or not provided. Specifically, we found that: ? For three of the 60 clients selected, the semi-annual re-assessment forms were not provided. ? For four of the 60 clients selected, the annual assessment forms were not provided. ? For one of the 60 clients selected, the annual assessment form was not signed by the case manager or supervisor. ? For two of the 60 clients selected, the document used to verify Hawaii residency was expired prior to initial service date. ? For one of the 60 clients selected, the document used to verify Hawaii residency was a Tongan passport. Based on the information provided, the client was not a Hawaii resident and was ineligible to receive services. ? For four of the 60 clients selected, lab results were used to temporarily document that the clients were HIV positive. No follow-up with a doctor or other HIV verification were provided. ? For one of the 60 clients selected, a bank statement was used for income determination. A bank statement alone does not document gross income as required to determine eligibility. ? For one of the 60 clients selected, a copy of a tax return transcript was used for income determination. Based on the information provided, this client?s annual income was above the poverty guideline and the client was ineligible to receive services. ? For five of the 60 clients selected, incomplete or no documentation was provided to verify income determination. ? For 18 of the 60 clients selected, no documentation was provided to verify that the payer of last resort requirement was met (i.e., that the services provided would not be covered by the client?s medical insurance provider). Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in the Health Resources and Services Administration?s HIV/AIDS Bureau Policy Clarification Notice No. 13-02 Clarifications on Ryan White Program Client Eligibility Determination and Recertification Requirements. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Cause HHHRC did not adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. As described in Finding 2021-001, HHHRC does not have formal policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process for the RWB program are reviewed by knowledgeable supervisors. Effect HHHRC did not comply with the RWB program eligibility requirements for the instances noted above. Questioned Costs Questioned costs for the clients that were not eligible to receive services noted above amounted to $702. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2020-01. Recommendation We recommend that HHHRC adhere to established policies and procedures requiring that appropriate documentation be received and maintained to evidence compliance with eligibility requirements during the in-take and re-assessment process for the RWB program. HHHRC should also consider developing a checklist to be completed at the time of in-take or re-assessment to ensure that all required documentation evidencing compliance with the RWB program eligibility requirements is obtained, reviewed, approved, and maintained in client files. Views of Responsible Officials and Planned Corrective Action HHHRC has integrated the recommendation of all new and re-certified participants of the RWB program will be reviewed by management to ensure that all eligibility documentation is appropriate and demonstrates eligibility for the RWB program. This policy has been integrated into HHHRC?s RWB manual and managers have been trained and developed workflow to implement and adhere to this practice. HHHRC?s policy and procedures do emphasize the importance of documenting RWB as the payor of last resort as required by the funding. In order to address this finding, HHHRC has provided training to all RWB staff about documentation of payor of last resort and added it to the checklist for the manager and peer reviews of charts for RWB. HHHRC has recently hired a Medical Billing Specialist which will be the final quality assurance check prior to any RWB service being billed and that will allow a third set of eyes within HHHRC?s finance department that all eligibility has been met, including documentation that every effort was made to find other sources of payment, including the patient?s health insurance.

2020-001

US Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, HI 96813 Hawaii Health & Harm Reduction Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30th, 2020 for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY, who are located at Topa Financial Center, 745 Fort Street, Suite 2100, Honolulu HI 96813 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Significant Deficiency Finding 2020-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 40 clients receiving assistance under the Ryan White HIV/AIDS Part B (RWB) program to ascertain whether those clients met the RWB program eligibility requirements. We noted that one of the 40 clients was ineligible to receive services under the RWB program. Criteria Clients receiving assistance under the RWB program are subject to eligibility requirements contained in Policy Clarification Notice No. 13-02. To be eligible, clients must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Cause During the in-take and re-assessment process, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents and verifying the RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. For the one instance noted above, the required forms and documents were received from the client, and the case manager correctly identified the client as ineligible based on income. However, this was not communicated between the departments servicing the client, resulting in the client receiving services approximating $2,170. Effect HHHRC did not comply with the RWB program eligibility requirements for the instance noted above. Questioned Costs Questioned costs of $2,170 were identified. Recommendation We recommend that HHHRC adhere to established policies and procedures requiring the timely notification of client eligibility between case managers and departments servicing clients to ensure that only individuals meeting the RWB program low-income eligibility requirements receive services. HHHRC should consider developing a checklist to be completed at the time of in-take or reassessment to ensure that all required documentation evidencing compliance with the RWB program eligibility requirements is obtained, reviewed, approved, and maintained in client files. Views of Responsible Officials and Planned Corrective Action HHHRC takes compliance with RWB program eligibility seriously and has implemented steps to improve internal policies, procedures/controls, training, and quality assurance practices to ensure incidents like these are mitigated and/or avoided. Moving forward, the HIV Case Management Team Lead will conduct periodic reviews of the expenditures to ensure all services billed to RWB are allowable and only made for RWB eligible clients. HHHRC?s clinical team will also document client?s eligibility within its electronic health record (EHR) system and codify this practice in its existing clinical processes. As for the identified questionable charge of $2,170. Per HHHRC?s internal investigation, it was determined that this situation was unique and involved an in-house referral to medical case management (MCM) from one of its Behavioral Health (BH) Provider. The Provider, upon assessment, identified the client as living with HIV. The client was then seen by an HIV Medical Case Manager who processed their eligibility for RWB funds. Client was verified to be ineligible due to income, however, this was not noted within the EHR. Therefore, the Provider was unaware of the client?s ineligible status and continued to mark the client?s mental health services to RWB within the e2Hawaii (E2) online HIV database. Accounting then billed Department of Health (DOH) $2,170.00 for RWB mental health services as noted within E2. Upon discovery, HHHRC reached out to DOH immediately for corrective action steps. Per DOH, HHHRC was to reimburse RWB with a credit on its following month?s invoice. HHHRC followed these instructions and credited back the erroneous charges with its February invoice. Corrective action has been completed and the issue of the questionable charge resolved.

CORRECTIVE ACTION PLAN February 18, 2019 U.S. Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, Hawaii 96813 Hawaii Health & Harm Reducation Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30, 2019, for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY LLC, who are located at Topa Finanical Center, 745 Fort Street, Suite 2100, Honolulu, Hawaii 96813. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2019-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During our audit, we selected a sample of 80 participants receiving assistance under the Ryan White HIV/AIDS Part B (RWB) program to ascertain whether those participants met the RWB program eligibility requirements. We noted that 5 of the 80 client files that did not contain documentation evidencing that the participants met the low-income eligibility requirement. Criteria Participants receiving assistance under the RWB program are subject to eligibility requirements contained in Policy Clarification Notice No. 13-02. To be eligible, participants must have a medical diagnosis of HIV/AIDS and be (a) a low-income individual, (b) a resident of the state, and (c) uninsured or underinsured, as defined by the state. Eligibility determination is required before participation in the RWB program during the in-take process. Re-assessments are performed at least once every 6 months thereafter. Cause During the in-take and re-assessment process, case managers are responsible for (1) ensuring that all required forms and documents are received from participants, (2) reviewing those forms and documents and verifying the RWB program eligibility requirements are met; and (3) inputting the participant?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program participants. The Clinical Director or the Case Management Team Manager then reviews and approves the in-take forms and documentation evidencing compliance with the RWB program eligibility requirements. For the 5 instances noted above, HHHRC did not adhere to established policies and procedures requiring that (1) documentation evidencing compliance with the RWB program low-income eligibility requirements be obtained and maintained in client files and (2) the Clinical Director or the Case Management Team Manager review and approve intake forms prepared by the case managers, including documentation evidencing compliance with the RWB program low-income eligibility requirement. Effect HHHRC did not comply with the RWB program eligibility requirements regarding the determination of low-income status for the 5 instances noted above. Questioned Costs No questioned or known costs were identified. Recommendation We recommend that HHHRC adhere to established policies and procedures requiring that documentation supporting compliance with the RWB program low-income eligibility requirements be obtained and maintained in client files and that the Clinical Director or the Case Management Team Manager review and approve intake forms prepared by the case managers, including documentation evidencing compliance with the RWB program low-income eligibility requirement. HHHRC should consider developing a checklist to be completed at the time of in-take or re-assessment to ensure that all required documentation evidencing compliance with the RWB program eligibility requirements is obtained, reviewed, approved, and maintained in client files. Action Taken HHHRC has already taken extensive action to address documentation of eligibility after the Department of Health?s Harm Reduction Services Branch conducted an annual audit of HHHRC?s Ryan White Part B (RWB) program and fiscal components in early 2019. Concerns from this site visit lead to an internal HHHRC audit in Spring 2019 that included HHHRC?s RWB Admin Team, consisting of the Operations Director, Policy & Contracts Manager, and Quality Coordinator, conduct an internal audit of its own. The overall audit focus is to identify, analyze, and correct any deficiencies in the areas of documentation, workflow, training, policies, and procedures. The findings of these were consistent with documentation irregularities and have led to changes in policies and procedures. HHHRC is has implemented the following measures as part of its correction action plan: HHHRC Case Managers review and update their files every 6 months. They also re-evaluate the client status, eligibility, and care plan every 6 months. HHHRC?s Quality Coordinator (QC) conducts monthly spots checks of client files, e2 data, and expenditures. If information is missing or in question, QC discusses the matter with client?s Case Manager to either correct the matter or get clarity. The QC also reviews expenditure reports to ensure funding is being spent to achieve the outcomes set forth by Ryan White Part B and that funding is spent appropriately and in compliance with RWB. Any major or repeated issues are discussed amongst the RWB Admin Team. HHHRC is developing a checklist to support Case Managers in assessing eligibility during intake or reassessment, which will be reviewed by the Clinical Director and QC annually which will be included in the client chart along with an update to policies and procedures to reflect this plan.