Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)).
Condition:
Legacy incorrectly assessed and/or applied the sliding fee discount to patient encounters during the year.
Questioned Costs:
None.
Context:
Three (3) of forty (40) encounters selected for testing.
Cause:
Unknown.
Effect:
Patients are not charged according to Legacy's sliding fee scale and their ability to pay.
Repeat Finding:
No.
Recommendation:
Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00;
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
Five (5) of five (5) procurement transactions selected for testing.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2022-002.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
Two (2) of two (2) vendors tested. Documentation was provided to show that sam.gov was checked, however it occurred on the last day of the fiscal year.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had be checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2022-003.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Vaccines Community-Based Education & Outreach (IVAX)
Assistance Listing Number: 93.268
Pass-Through Entity: Illinois Primary Health Care Association
Pass-Through Number: N/A
Award Periods: July 1, 2022 – March 31, 2023
Type of Finding: Immaterial Noncompliance and Significant deficiency in internal control over compliance
Criteria:
A non-Federal entity that does not have a current negotiated indirect cost rate, may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. No documentation is required to justify the 10% de minimis indirect cost rate. As described in § 200.403, costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time.
Condition:
Legacy incorrectly calculated the reimbursement of in-direct costs when using the de minimis rate of 10%.
Questioned Costs:
$3,404.
Context:
Three (3) of three (3) in-direct cost transactions selected for testing.
Cause:
Unknown.
Effect:
Calculating indirect costs incorrectly could result in unallowable costs being charged to the grant.
Repeat Finding:
No.
Recommendation:
We recommend that a member of management review the monthly calculation of indirect costs to ensure it is calculated correctly.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Vaccines Community-Based Education & Outreach (IVAX)
Assistance Listing Number: 93.268
Pass-Through Entity: Illinois Primary Health Care Association
Pass-Through Number: N/A
Award Periods: July 1, 2022 – March 31, 2023
Type of Finding: Immaterial Noncompliance and Significant deficiency in internal control over compliance
Criteria:
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods.
Condition:
Costs outside of the period of performance were charged to the grant.
Questioned Costs:
$4,279
Context:
Four (4) of seven (7) transactions tested.
Cause:
Unknown
Effect:
Legacy may allocate unallowable costs to the federal grant.
Repeat Finding:
Yes.
Prior Year Finding:
2022-004.
Recommendation:
We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by days worked within the grant period.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)).
Condition:
Legacy incorrectly assessed and/or applied the sliding fee discount to patient encounters during the year.
Questioned Costs:
None.
Context:
Three (3) of forty (40) encounters selected for testing.
Cause:
Unknown.
Effect:
Patients are not charged according to Legacy's sliding fee scale and their ability to pay.
Repeat Finding:
No.
Recommendation:
Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00;
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
Five (5) of five (5) procurement transactions selected for testing.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2022-002.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
Two (2) of two (2) vendors tested. Documentation was provided to show that sam.gov was checked, however it occurred on the last day of the fiscal year.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had be checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2022-003.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Vaccines Community-Based Education & Outreach (IVAX)
Assistance Listing Number: 93.268
Pass-Through Entity: Illinois Primary Health Care Association
Pass-Through Number: N/A
Award Periods: July 1, 2022 – March 31, 2023
Type of Finding: Immaterial Noncompliance and Significant deficiency in internal control over compliance
Criteria:
A non-Federal entity that does not have a current negotiated indirect cost rate, may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. No documentation is required to justify the 10% de minimis indirect cost rate. As described in § 200.403, costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time.
Condition:
Legacy incorrectly calculated the reimbursement of in-direct costs when using the de minimis rate of 10%.
Questioned Costs:
$3,404.
Context:
Three (3) of three (3) in-direct cost transactions selected for testing.
Cause:
Unknown.
Effect:
Calculating indirect costs incorrectly could result in unallowable costs being charged to the grant.
Repeat Finding:
No.
Recommendation:
We recommend that a member of management review the monthly calculation of indirect costs to ensure it is calculated correctly.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Vaccines Community-Based Education & Outreach (IVAX)
Assistance Listing Number: 93.268
Pass-Through Entity: Illinois Primary Health Care Association
Pass-Through Number: N/A
Award Periods: July 1, 2022 – March 31, 2023
Type of Finding: Immaterial Noncompliance and Significant deficiency in internal control over compliance
Criteria:
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods.
Condition:
Costs outside of the period of performance were charged to the grant.
Questioned Costs:
$4,279
Context:
Four (4) of seven (7) transactions tested.
Cause:
Unknown
Effect:
Legacy may allocate unallowable costs to the federal grant.
Repeat Finding:
Yes.
Prior Year Finding:
2022-004.
Recommendation:
We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by days worked within the grant period.
Views of Responsible Officials:
There is no disagreement with the audit finding.