Monitoring Compliance for Ryan White Part A Client Income and Residency Eligibility

1. Monitoring Compliancefor Ryan White Part AClient Income and Residency Eligibility Bettina Carroll Director for Programs and Contract Management HIV Care Services/Public Health Solutions September 18, 2012

2. Background • April 2011 HRSA implemented Monitoring Standards for RW Part A/B grantees • Introduction of Eligibility Determination Screening process • Programs required to assess and maintain documentation of client eligibility including: • proof of income-based on EMA-developed criteria • proof of residency-within the five boroughs of NYC, Westchester, Rockland and Putnam counties

3. Implementation Process • New York City Department of Health and Mental Hygiene Bureau of HIV/AIDS Prevention and Control (DOHMH/BHIV) issued correspondence to providers (10/31/11 and 12/16/11): Documentation of Proof of Residency • Policy overview (including exempt service categories) • Process for implementation of process • Timeline for implementation of process • Overview of acceptable documentation

4. Implementation Process (cont’d) • JoAnn Hilger, MPH/DOHMH, presented HRSA Monitoring Standards for Ryan White Part A & B Grantees to the HIVCS CAG on October 26, 2011 • Clients will be subject to income eligibility standards starting March 1, 2012 • Clients will be required to provide evidence of EMA residency for eligibility starting March 1, 2012 • HIV Care Services Contractor Newsflash – December 2011 - detailed client eligibility review and documentation process to be initiated as of March 1, 2012

5. Implementation Process (cont’d) • Amended Contract Scope of Services language with FY 22 contract renewals • Initiated monitoring of compliance as of March 1, 2012 • Provided technical assistance to programs regarding implementation • Documented “recommendations” for compliance in site visit reports • Postponed implementation of compliance actions until September 2012

6. Site Visit Monitoring of Eligibility Check Compliance

7. Issues related to compliance(feedback from providers) • Client resistance to/fear about providing documentation • Time consuming process (particularly with “old” clients) • Difficulty getting documents from homeless clients • Difficult to obtain copy of documents for clients seen in the home; innovative methods may breach confidentiality

8. Issues related to compliance(feedback from providers cont’d) • Unaware of/confused about when requirements for eligibility checks should be implemented • Unaware of acceptable documentation for eligibility checks • Transient population (inconsistent attendees) • Clients forget to bring documentation

9. Questions from programs regarding documentation of eligibility • Can e-PACES be used to verify residency and income eligibility? • Can transportation logs be used for residency documentation? • If the same documentation is used to establish eligibility in successive years (no status change), is it necessary to re-copy documents? • Can mail from the program sent to a client’s address be used as proof of residency?

10. Questions from programs regarding documentation of eligibility (cont’d) • Can a HASA referral letter document residency and income eligibility? • Can identification cards for other health insurance, with Medicaid-similar income criteria, be used to document income eligibility?

11. Best Programs Practices • Development of a form/checklist of documents needed to enroll clients • Development of “eligibility documentation” section created in the client record • Development of Attestation Form detailing required elements as statements; used at point of reassessment

12. Sample Attestation Form: courtesy of HHC Harlem Hospital

13. Next Steps • HIVCS and DOHMH will review current process and need to revise the scope amendment to adjust documentation requirements: • Inclusion of additional acceptable documentation • Process to collect/reflect documentation

14. Questions for the CAG • What barriers have you found in implementing the process? • How have you addressed these concerns? • Are there suggestions for eligibility documentation which we have not considered?