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.