Audit 14360

FY End
2022-11-30
Total Expended
$6.27M
Findings
10
Programs
7
Year: 2022 Accepted: 2024-01-30

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
10682 2022-001 Significant Deficiency Yes C
10683 2022-002 Significant Deficiency Yes N
10684 2022-003 Significant Deficiency - I
10685 2022-004 - - L
10686 2022-005 - Yes L
587124 2022-001 Significant Deficiency Yes C
587125 2022-002 Significant Deficiency Yes N
587126 2022-003 Significant Deficiency - I
587127 2022-004 - - L
587128 2022-005 - Yes L

Contacts

Name Title Type
GFJMVJX6KC93 Tyson Bouyack Auditee
4197207883 Diann Stretten Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Association does not apply indirect costs to the grants. The accompanying schedule of expenditures of federal awards, which includes all federal grant activity of the Association, is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used, in the preparation of the consolidated financial statements.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Association does not apply indirect costs to the grants. Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Association has elected not to use the ten-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Provider Relief Funds Accounting Policies: Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Association does not apply indirect costs to the grants. The Organization received $53,659 in DHHS Provider Relief Fund (PRF) and American Rescue Plan (“ARP”) Rural Distribution (Federal Assistance Listing #93.498) during the year ended November 30, 2022. The Organization incurred eligible expenditures and lost revenue and therefore recognized the revenue of $53,659 on the consolidated statement of activities and changes in net assets for the year ended November 30, 2022. However, the PRF expenditures were not recognized on the Schedule of Expenditures of Federal Awards for the fiscal year ended November 30, 2022, as the OMB Compliance Supplement of 2022 requires the federal expenditures to be excluded from the Schedule of Expenditures of Federal Awards (“SEFA”) until the applicable reporting period as outlined by DHHS. Amounts presented on the SEFA for the year ended November 30, 2022, of $29,313 were presented in revenue on the consolidated statement of activities and changes in net assets for the fiscal year ended November 30, 2021.

Finding Details

Finding 2022-001 – Cash Management Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific requirement-criteria Under cash management of federal funds, when funded under the reimbursement method, funds reimbursed under a federal program should be paid or incurred by the Organization prior to the date for which reimbursement was requested, or within the program’s specified time frame. Condition-context In a sample of two request for federal fund draws (draws) under cash management, we noted that one draw included four voided checks that totaled $41,133. The voided checks had been reissued and included on a subsequent draw request as well. Accordingly, the cash disbursements were mistakenly reimbursed twice. The organization was able to identify additional qualifying payroll expenses that occurred in the months of April 2022, May 2022, and June 2022. Cause Due to open positions in the finance department, untimely reconciliation of expenses charged to the grants, misstatements, intentional or unintentional, occurred during fiscal year 2022. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information up to date. The vacancies caused catch up to be completed by the contracted financial consultants. Effect or potential effect Risk that unapproved or unallowable expenditures are reimbursed by federal agency. Questioned costs None Repeat finding Yes, see finding 2021-002.
Finding 2022-002 – Special Tests & Provisions Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific requirement-criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients’ ability to pay. Condition-context During a sample of sixty patient encounter visits; we noted the following errors: 1) two encounter visits were provided a sliding fee; however, both did not have the applicable sliding fee application and the sliding fee was applied to their patient account; 2) three encounter visits that qualified for a Homeless patient adjustment to zero were provided a sliding fee adjustment and, accordingly, the patient account was not slid to zero; and 3) a sliding fee adjustment applied to a patient’s account was applied at the incorrect amount per the Association’s sliding fee scale. Cause Due to the employee turnover within the front desk and the finance department, the Organization has had difficulty in training and assuring skilled intake staff are correctly applying the sliding fees. Effect or potential effect Applicants assessed are not charged according to the Association’s sliding fee scale and ability to pay. Questioned costs None. Repeat finding Yes, see finding 2021-003.
Finding 2022-003 – Suspension & Debarment Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Significant deficiency in internal control over compliance Specific requirement-criteria Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected four of four parties selected for testing. The Organization did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat finding No.
Finding 2022-004 – Reporting Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific requirement - criteria The Association is required to submit Federal Financial Reports (SF-425 FFR) on an annual and final basis for grant periods. Condition - context In a sample of four reports, the following two, of the required Federal Financial Report (SF-425 FFR), were not submitted within the required time frame: Cause Due to open positions in the finance department, untimely completion of internal financial reporting occurred during fiscal year 2021 and 2022, accordingly the financial records were being brought up to date to ensure accuracy in reporting on the FFR, resulting in late data to be available for reporting on the FFRs. During 2022, the Associate hired contract financial consultants to aid in the open positions and bring financial information up to date. Effect Noncompliance with the grant agreement requirement reporting due dates. Questioned Costs None. Repeat finding No.
Finding 2022-005 – Data Collection Form Submission Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific requirement-criteria The Organization is required to file their audit reporting package and the data collection form thirty days after receipt of the auditor’s report or nine months after the end of their fiscal year, whichever comes first. Condition - context Due to employee turnover in the finance department, the audit was issued in September 2023 and, therefore, the audit reporting package and the data collection form were submitted late. Cause Due to employee turnover in the finance department, the Organization needed additional time to complete the audit schedules while maintaining current operations with their limited staff. Effect or potential effect The audit was issued in September 2023 and, therefore, the audit reporting package and the data collection form were submitted late. Questioned costs None. Repeat finding Yes, see Finding 2021-004.
Finding 2022-001 – Cash Management Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific requirement-criteria Under cash management of federal funds, when funded under the reimbursement method, funds reimbursed under a federal program should be paid or incurred by the Organization prior to the date for which reimbursement was requested, or within the program’s specified time frame. Condition-context In a sample of two request for federal fund draws (draws) under cash management, we noted that one draw included four voided checks that totaled $41,133. The voided checks had been reissued and included on a subsequent draw request as well. Accordingly, the cash disbursements were mistakenly reimbursed twice. The organization was able to identify additional qualifying payroll expenses that occurred in the months of April 2022, May 2022, and June 2022. Cause Due to open positions in the finance department, untimely reconciliation of expenses charged to the grants, misstatements, intentional or unintentional, occurred during fiscal year 2022. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information up to date. The vacancies caused catch up to be completed by the contracted financial consultants. Effect or potential effect Risk that unapproved or unallowable expenditures are reimbursed by federal agency. Questioned costs None Repeat finding Yes, see finding 2021-002.
Finding 2022-002 – Special Tests & Provisions Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific requirement-criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients’ ability to pay. Condition-context During a sample of sixty patient encounter visits; we noted the following errors: 1) two encounter visits were provided a sliding fee; however, both did not have the applicable sliding fee application and the sliding fee was applied to their patient account; 2) three encounter visits that qualified for a Homeless patient adjustment to zero were provided a sliding fee adjustment and, accordingly, the patient account was not slid to zero; and 3) a sliding fee adjustment applied to a patient’s account was applied at the incorrect amount per the Association’s sliding fee scale. Cause Due to the employee turnover within the front desk and the finance department, the Organization has had difficulty in training and assuring skilled intake staff are correctly applying the sliding fees. Effect or potential effect Applicants assessed are not charged according to the Association’s sliding fee scale and ability to pay. Questioned costs None. Repeat finding Yes, see finding 2021-003.
Finding 2022-003 – Suspension & Debarment Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Significant deficiency in internal control over compliance Specific requirement-criteria Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected four of four parties selected for testing. The Organization did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat finding No.
Finding 2022-004 – Reporting Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific requirement - criteria The Association is required to submit Federal Financial Reports (SF-425 FFR) on an annual and final basis for grant periods. Condition - context In a sample of four reports, the following two, of the required Federal Financial Report (SF-425 FFR), were not submitted within the required time frame: Cause Due to open positions in the finance department, untimely completion of internal financial reporting occurred during fiscal year 2021 and 2022, accordingly the financial records were being brought up to date to ensure accuracy in reporting on the FFR, resulting in late data to be available for reporting on the FFRs. During 2022, the Associate hired contract financial consultants to aid in the open positions and bring financial information up to date. Effect Noncompliance with the grant agreement requirement reporting due dates. Questioned Costs None. Repeat finding No.
Finding 2022-005 – Data Collection Form Submission Federal program and specific federal award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific requirement-criteria The Organization is required to file their audit reporting package and the data collection form thirty days after receipt of the auditor’s report or nine months after the end of their fiscal year, whichever comes first. Condition - context Due to employee turnover in the finance department, the audit was issued in September 2023 and, therefore, the audit reporting package and the data collection form were submitted late. Cause Due to employee turnover in the finance department, the Organization needed additional time to complete the audit schedules while maintaining current operations with their limited staff. Effect or potential effect The audit was issued in September 2023 and, therefore, the audit reporting package and the data collection form were submitted late. Questioned costs None. Repeat finding Yes, see Finding 2021-004.