Audit 15598

FY End
2022-03-31
Total Expended
$8.31M
Findings
10
Programs
13
Organization: Family First Health Corporation (PA)
Year: 2022 Accepted: 2024-02-05
Auditor: Cohnreznick LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
11767 2022-003 Significant Deficiency - AB
11768 2022-003 Significant Deficiency - AB
11769 2022-003 Significant Deficiency - AB
11770 2022-003 Significant Deficiency - AB
11771 2022-004 Significant Deficiency - L
588209 2022-003 Significant Deficiency - AB
588210 2022-003 Significant Deficiency - AB
588211 2022-003 Significant Deficiency - AB
588212 2022-003 Significant Deficiency - AB
588213 2022-004 Significant Deficiency - L

Contacts

Name Title Type
JE8YCDAQV681 Brent Doores Auditee
7178014809 Karen Harris Auditor
No contacts on file

Notes to SEFA

Title: COVID-19 - Provider Relief Fund and American Rescue Plan ("ARP") Rural Distribution - Assistance Listing Number 93.498 Accounting Policies: The accompanying Schedule of Expenditures of Awards (the "Schedule") includes the federal award activity of Family First Health Corporation (the "Center") under programs of the federal government for the year ended March 31, 2022. 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"). Because the Schedule presents only a selected portion of the operations of the Center, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Center. De Minimis Rate Used: N Rate Explanation: 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 reimbursements. The Center did not elect to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. For the Department of Health and Human Services ("DHHS") awards related to the Provider Relief Fund and American Rescue Plan ("ARP") Rural Distribution ("PRF") program, DHHS has indicated the amounts on the Schedule be reported corresponding to reporting requirements of the HRSA PRF Reporting Portal. Payments from DHHS for PRF are assigned to 'Payment Received Periods' (each, a Period) based upon the date each payment from the PRF was received. Each Period has a specified Period of Availability and timing of reporting requirements. Entities report into the HRSA PRF Reporting Portal after each Period's deadline to use the funds (i.e., after the end of the Period of Availability). The Schedule includes $229,291 received from DHHS between April 1, 2020 and June 30, 2020. In accordance with guidance from DHHS, this amount represents funding for Period 1. Such amounts were recognized as DHHS grant revenue in the financial statements for the year ended March 31, 2021.
Title: Restatement Accounting Policies: The accompanying Schedule of Expenditures of Awards (the "Schedule") includes the federal award activity of Family First Health Corporation (the "Center") under programs of the federal government for the year ended March 31, 2022. 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"). Because the Schedule presents only a selected portion of the operations of the Center, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Center. De Minimis Rate Used: N Rate Explanation: 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 reimbursements. The Center did not elect to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Schedule, previously issued on December 21, 2022, has been restated because the Schedule improperly excluded $707,583 of expenditures related to the COVID-19 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number 93.224. The Schedule has been corrected to include this amount.

Finding Details

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Center is required to accurately report to HRSA the methodology applied to the provider relief funds received. Condition/Context: In connection with the Reporting test for the Provider Relief Funds, we noted that the Center inaccurately reported the methodology used to HRSA as expenditures attributable to coronavirus as opposed to lost revenues. Cause: Personnel in charge of the submission inadvertently reported the incorrect methodology. Effect: HRSA could deem the report to be invalid and require the Center to pay back the funds. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the reporting over the provider relief funds is accurate prior to submission. Views of Responsible Officials: Procedures will be put in place to review accuracy of reporting prior to submission.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster, COVID-19 Immunization Cooperative Agreements Federal Assistance Listing Number: 93.224, 93.527, 93.268 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The time and effort attestations are to be prepared and signed by the employees who work on the grants and their supervisor on a timely basis. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the DHHS 330 grant and the PA DOH COVID vaccine grant, we noted that the time and effort attestations for all employees were not done until the time of the audit. Cause: Due to turnover in the finance department, the attestations were not completed until they were requested by the auditors. Effect or Potential Effect: The deficiency in the Center's controls over compliance with activities allowed or unallowed, and allowable cost/cost principles could result in unallowed payroll costs being charged to the grant. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the time and effort attestations are signed by both employee and supervisor timely. Views of Responsible Officials: Family First Health will review its Time and Effort policy to ensure continued compliance with federal regulations in maintaining records of personnel time and effort to substantiate salary costs associated with its federal grants. We will add steps to our process to ensure that the certifications by employees whose time is allocated to one federally funded program will sign an after-the-fact certification on a semi-annual basis confirming that the employee worked on a single award for the given period. The transition from ADP (our past payroll processor) to Paycom (our new payroll processor) will provide additional levels of timekeeping detail that will enable time and effort to be more closely monitored and reported.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Center is required to accurately report to HRSA the methodology applied to the provider relief funds received. Condition/Context: In connection with the Reporting test for the Provider Relief Funds, we noted that the Center inaccurately reported the methodology used to HRSA as expenditures attributable to coronavirus as opposed to lost revenues. Cause: Personnel in charge of the submission inadvertently reported the incorrect methodology. Effect: HRSA could deem the report to be invalid and require the Center to pay back the funds. Questioned Costs: None Identification as a Repeat Finding No Auditor's Recommendation: The Center should ensure that the reporting over the provider relief funds is accurate prior to submission. Views of Responsible Officials: Procedures will be put in place to review accuracy of reporting prior to submission.