The Ohio Association of Foodbanks Generally Complied With the Navigator Requirements Related to the Affordable Care Act

The Ohio Association of Foodbanks (Ohio Foodbanks) assists consumers with obtaining healthcare coverage through the marketplaces and provides consumers with information about insurance affordability programs. Navigator assistance personnel (navigators) also work to raise awareness about the marketplaces and refer consumers to health insurance ombudsmen and consumer assistance programs when necessary. Ohio Foodbanks received approximately $2 million in Federal funds for the grant period ended August 14, 2014, of which $1.6 million was provided to 11 subgrantees.

Ohio Foodbanks' navigators generally met the navigator eligibility requirements, and its expenditures were generally allowable under the terms of the Affordable Care Act navigator grant and applicable Federal and State regulations. However, of the $1.6 million claimed by the subgrantees, we determined $10,500 to be unallowable, which included (1) $1,700 previously reimbursed during the grant period, (2) $5,000 that was not incurred during the grant period, (3) $1,200 in grant funds paid to a subgrantee for services that were never provided, (4) $1,000 in expenditures inappropriately charged to the grant, and (5) $1,600 in costs not adequately supported. The unallowable costs were due to Ohio Foodbanks' insufficient monitoring of the subgrantees' expenditures, which resulted in a limited number of inappropriate or inadequately supported costs.

We recommended that CMS (1) require Ohio Foodbanks to refund $1,700 to the Federal Government for costs previously reimbursed within the grant period, (2) require Ohio Foodbanks to refund $5,000 to the Federal Government for costs not incurred during the grant period,

(3) require Ohio Foodbanks to refund $1,200 to the Federal Government for grant funds paid to a subgrantee for services that were never provided, (4) require Ohio Foodbanks to refund $1,000 to the Federal Government for expenditures inappropriately charged to the grant, (5) require Ohio Foodbanks to refund $1,600 to the Federal Government for costs not adequately supported, and (6) work with Ohio Foodbanks to strengthen its procedures for monitoring subgrantee costs to ensure that claimed costs adhere to applicable Federal requirements. Ohio Foodbanks generally agreed with our findings and all but two of our recommendations.