Recurring Findings

Public Health: Recurring Most severe Noncompliance
Federal Program Issue First Year Reported
Department's Assertion Page Number
HIV Care Formula Grants Eligibility. Out of 60 beneficiaries reviewed, 7 beneficiaries did not submit all required documentation, including income documentation and medical reports, to prove that they have a positive HIV/AIDS diagnosis or their annual Modified Adjusted Gross Income did not exceed 500 percent of the Federal Poverty Level based on household size and income. These individuals were placed on a 30- day temporary access period but continued to receive full benefits from the program after the temporary access period ended. In December 2018, the HIV Care Formula Grants unit updated the Aids Drug Assistance Program (ADAP) guidelines to include a secondary review of ADAP applications that requiresa review of specified eligibility criteria. The ADAP Branch should continue to monitor compliance with its policies to ensure enrollment workers follow the established guidelines and retain acceptable documentation to support eligibility determinations. 2017-18
Partially Corrected – repeat finding – refer to finding 2019-006. Secondary review was implemented in the ADAP Enrollment System for ADAP Advisors. Secondary review is the process in which an ADAP Advisor reviews an application to ensure that the client provided all necessary documents to substantiate eligibility for ADAP (i.e., proof of identification, proof of California residency, proof of income, clinical information, third party pay or information). ADAP Advisors review 100 percent of ADAP applications which includes initial ADAP applications and re-enrollment applications that have not been granted an eligibility exception (i.e., Temporary Access Period, Medi-Cal Eligibility Exception Request, or Eligibility Exception Request) on a daily basis. As part of the secondary review process, ADAP Advisors complete their review of the application and are required to document the outcome. ADAP Advisors must select whether the application passed review, the client was placed on temporary access period, or whether the client was disenrolled. 37
Immunization Grants Special Tests and Provisions. All Vaccines for Children Program (VFC) providers must receive a VFC compliance site visit every 24 months. For the period January 1, 2017 to June 30, 2018, there were 278 active providers that were overdue for a site visit and 297 overdue follow-up actions. The Immunization Branch of Public Health should develop and implement a plan to perform the VFC compliance site visits, including any follow-up actions, within the required timeframe. 2017-18
Partially Corrected – repeat finding – refer to 2019-008. The Public Health Immunization Branch has moved one additional VFC position to Southern California and is providing additional assistance from other regions as time and workload permits. As of October 5, 2020, 828 providers are overdue for a site visit due to the pandemic. Public Health’s goal is to continually reduce the number of overdue site visits until all providers are current and establish a system to ensure providers are visited on a rotational basis. Follow-up actions are mandatory corrective actions (MCAs) that the providers must implement. Follow-up actions are identified during compliance visits and providers are given a timeframe in which they must complete the action. Providers can be suspended or placed on hold because of failure to complete MCAs. As part of Public Health’s 2019 VFC recertification process, a provider cannot recertify if it is on suspension for outstanding MCAs over one year. Field staff are prompted monthly to contact providers with overdue MCAs. Given that the program is required to continue conducting visits to providers on a timely schedule, and to ensure that more providers do not become overdue, Public Health will continue to prioritize provider visits per CDC requirements. In March 2020, as the pandemic necessitated shelter-in-place orders throughout California, the program paused in-person visit activities to follow CDC guidelines of social distancing and to protect the health of our staff and program participants. Once visits have returned to normal and we have received guidance from CDC around expectations for missed visits during the pandemic, we will assess our staffing and determine if additional changes are needed. We will also need to be diligent in our process to dis-enroll providers who have not completed their mandatory corrective actions. 42