Audit 306968

SLIDING FEE DISCOUNT DOCUMENTATION.Type of Finding: (E) Significant Deficiency in Internal Control Over Compliance of Federal Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Special Tests and Provisions: Sliding Fee Discounts Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition During our testing of compliance of federal awards, we noted income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. Criteria Per the Uniform Guidance compliance supplement, “Review a sample of financial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the health center’s sliding fee discount schedule. (Note: Auditors are not required to test any documentation used to establish or verify income). Effect Without ensuring a thorough examination of the patient's income information inputted into the system, there is high risk that MVCHS is applying an incorrect sliding fee discount for health center services provided to individuals and families. Cause In 2023, MVCHS experienced significant turnover at the Front Office, where patient registration is completed. Due to a lack of continuity in staffing, the processes for acquiring documentation related to Sliding Fee Discount Program were inconsistent. Staff turnover, coupled with shut down due to wildfires and flooding, as well as a national pandemic, caused havoc on operation. Recommendation To ensure compliance with federal regulations, MVCHS should ensure that proper income documentation for the Sliding Fee Discount Program is collected regularly from patients and updated in accordance with the corresponding Policy. Training should be provided to staff members regarding the collection and recording of income information for the Sliding Fee Discount Program, and finance and billing staff should perform oversight. Management Response MVCHS recognizes that in 2023 income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. 1. MVCHS will also ensure that required income documents are obtained and that the correct income (s) are applied. MVCHS will also ensure that patients who are unable to provide written verification at the time of their first appointment will complete the self-declaration portion of the SFDP application. 2. MVCHS will provide training to Front Office staff to ensure that income and family size are properly entered into the system and the Slide is properly applied. MVCHS will ensure that proper documentation is collected from patients and that accurate information is entered into the system, even during staff turnover. Finance/Billing staff will ensure oversite of documentation. 3. MVCHS reached out to the New Mexico Primary Care Association and was provided training for the Front Office Staff regarding the Sliding Fee Discount Program process in April 2024. DRAFT

SLIDING FEE DISCOUNT DOCUMENTATION.Type of Finding: (E) Significant Deficiency in Internal Control Over Compliance of Federal Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Special Tests and Provisions: Sliding Fee Discounts Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition During our testing of compliance of federal awards, we noted income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. Criteria Per the Uniform Guidance compliance supplement, “Review a sample of financial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the health center’s sliding fee discount schedule. (Note: Auditors are not required to test any documentation used to establish or verify income). Effect Without ensuring a thorough examination of the patient's income information inputted into the system, there is high risk that MVCHS is applying an incorrect sliding fee discount for health center services provided to individuals and families. Cause In 2023, MVCHS experienced significant turnover at the Front Office, where patient registration is completed. Due to a lack of continuity in staffing, the processes for acquiring documentation related to Sliding Fee Discount Program were inconsistent. Staff turnover, coupled with shut down due to wildfires and flooding, as well as a national pandemic, caused havoc on operation. Recommendation To ensure compliance with federal regulations, MVCHS should ensure that proper income documentation for the Sliding Fee Discount Program is collected regularly from patients and updated in accordance with the corresponding Policy. Training should be provided to staff members regarding the collection and recording of income information for the Sliding Fee Discount Program, and finance and billing staff should perform oversight. Management Response MVCHS recognizes that in 2023 income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. 1. MVCHS will also ensure that required income documents are obtained and that the correct income (s) are applied. MVCHS will also ensure that patients who are unable to provide written verification at the time of their first appointment will complete the self-declaration portion of the SFDP application. 2. MVCHS will provide training to Front Office staff to ensure that income and family size are properly entered into the system and the Slide is properly applied. MVCHS will ensure that proper documentation is collected from patients and that accurate information is entered into the system, even during staff turnover. Finance/Billing staff will ensure oversite of documentation. 3. MVCHS reached out to the New Mexico Primary Care Association and was provided training for the Front Office Staff regarding the Sliding Fee Discount Program process in April 2024. DRAFT

(E) Significant Deficiency in Internal Control Over Compliance of Federal. Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Procurement and Suspension and Debarment Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition MVCHS did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. During our test work, it was noted that 4 out of 4 tests of internal control over compliance, MVCHS did not screen vendors for compliance with suspension and debarment requirements. Criteria MVCHS is required to verify that entities it plans to do business with are not excluded or disqualified under the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §75.303 Internal controls of 45 CFR Part 75, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to §75.327 general procurement standards of 45 CFR Part 75, the nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity MVCHS must establish and maintain effective internal control over the Federal award that provides reasonable assurance MVCHS is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can been done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Internal controls over compliance do not appear to have been adequately implemented due to lack of training, oversight, or resources. Effect The Institute may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend that the organization: View of Responsible Officials MVCHS acknowledges the need to implement procedures to verify the suspension and debarment status of contractors prior to using federal funds. The Finance Department will develop a process to check for suspension and debarment prior to issuing a purchase order. This process will be completed by May 6, 2024. Carla Melendez, Chief Financial Officer will be responsible for developing and implementing this process. • follow its policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • include the required suspension and debarment clause in its contracts with contractors using federal funds.

(E) Significant Deficiency in Internal Control Over Compliance of Federal. Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Procurement and Suspension and Debarment Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition MVCHS did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. During our test work, it was noted that 4 out of 4 tests of internal control over compliance, MVCHS did not screen vendors for compliance with suspension and debarment requirements. Criteria MVCHS is required to verify that entities it plans to do business with are not excluded or disqualified under the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §75.303 Internal controls of 45 CFR Part 75, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to §75.327 general procurement standards of 45 CFR Part 75, the nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity MVCHS must establish and maintain effective internal control over the Federal award that provides reasonable assurance MVCHS is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can been done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Internal controls over compliance do not appear to have been adequately implemented due to lack of training, oversight, or resources. Effect The Institute may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend that the organization: View of Responsible Officials MVCHS acknowledges the need to implement procedures to verify the suspension and debarment status of contractors prior to using federal funds. The Finance Department will develop a process to check for suspension and debarment prior to issuing a purchase order. This process will be completed by May 6, 2024. Carla Melendez, Chief Financial Officer will be responsible for developing and implementing this process. • follow its policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • include the required suspension and debarment clause in its contracts with contractors using federal funds.

SLIDING FEE DISCOUNT DOCUMENTATION.Type of Finding: (E) Significant Deficiency in Internal Control Over Compliance of Federal Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Special Tests and Provisions: Sliding Fee Discounts Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition During our testing of compliance of federal awards, we noted income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. Criteria Per the Uniform Guidance compliance supplement, “Review a sample of financial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the health center’s sliding fee discount schedule. (Note: Auditors are not required to test any documentation used to establish or verify income). Effect Without ensuring a thorough examination of the patient's income information inputted into the system, there is high risk that MVCHS is applying an incorrect sliding fee discount for health center services provided to individuals and families. Cause In 2023, MVCHS experienced significant turnover at the Front Office, where patient registration is completed. Due to a lack of continuity in staffing, the processes for acquiring documentation related to Sliding Fee Discount Program were inconsistent. Staff turnover, coupled with shut down due to wildfires and flooding, as well as a national pandemic, caused havoc on operation. Recommendation To ensure compliance with federal regulations, MVCHS should ensure that proper income documentation for the Sliding Fee Discount Program is collected regularly from patients and updated in accordance with the corresponding Policy. Training should be provided to staff members regarding the collection and recording of income information for the Sliding Fee Discount Program, and finance and billing staff should perform oversight. Management Response MVCHS recognizes that in 2023 income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. 1. MVCHS will also ensure that required income documents are obtained and that the correct income (s) are applied. MVCHS will also ensure that patients who are unable to provide written verification at the time of their first appointment will complete the self-declaration portion of the SFDP application. 2. MVCHS will provide training to Front Office staff to ensure that income and family size are properly entered into the system and the Slide is properly applied. MVCHS will ensure that proper documentation is collected from patients and that accurate information is entered into the system, even during staff turnover. Finance/Billing staff will ensure oversite of documentation. 3. MVCHS reached out to the New Mexico Primary Care Association and was provided training for the Front Office Staff regarding the Sliding Fee Discount Program process in April 2024. DRAFT

SLIDING FEE DISCOUNT DOCUMENTATION.Type of Finding: (E) Significant Deficiency in Internal Control Over Compliance of Federal Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Special Tests and Provisions: Sliding Fee Discounts Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition During our testing of compliance of federal awards, we noted income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. Criteria Per the Uniform Guidance compliance supplement, “Review a sample of financial records for patients treated during the audit period to determine whether patient charges were appropriately adjusted based on income and family size by applying the health center’s sliding fee discount schedule. (Note: Auditors are not required to test any documentation used to establish or verify income). Effect Without ensuring a thorough examination of the patient's income information inputted into the system, there is high risk that MVCHS is applying an incorrect sliding fee discount for health center services provided to individuals and families. Cause In 2023, MVCHS experienced significant turnover at the Front Office, where patient registration is completed. Due to a lack of continuity in staffing, the processes for acquiring documentation related to Sliding Fee Discount Program were inconsistent. Staff turnover, coupled with shut down due to wildfires and flooding, as well as a national pandemic, caused havoc on operation. Recommendation To ensure compliance with federal regulations, MVCHS should ensure that proper income documentation for the Sliding Fee Discount Program is collected regularly from patients and updated in accordance with the corresponding Policy. Training should be provided to staff members regarding the collection and recording of income information for the Sliding Fee Discount Program, and finance and billing staff should perform oversight. Management Response MVCHS recognizes that in 2023 income for 4 out of 30 patients was incorrectly entered into the system and the slide was improperly applied. 1. MVCHS will also ensure that required income documents are obtained and that the correct income (s) are applied. MVCHS will also ensure that patients who are unable to provide written verification at the time of their first appointment will complete the self-declaration portion of the SFDP application. 2. MVCHS will provide training to Front Office staff to ensure that income and family size are properly entered into the system and the Slide is properly applied. MVCHS will ensure that proper documentation is collected from patients and that accurate information is entered into the system, even during staff turnover. Finance/Billing staff will ensure oversite of documentation. 3. MVCHS reached out to the New Mexico Primary Care Association and was provided training for the Front Office Staff regarding the Sliding Fee Discount Program process in April 2024. DRAFT

(E) Significant Deficiency in Internal Control Over Compliance of Federal. Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Procurement and Suspension and Debarment Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition MVCHS did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. During our test work, it was noted that 4 out of 4 tests of internal control over compliance, MVCHS did not screen vendors for compliance with suspension and debarment requirements. Criteria MVCHS is required to verify that entities it plans to do business with are not excluded or disqualified under the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §75.303 Internal controls of 45 CFR Part 75, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to §75.327 general procurement standards of 45 CFR Part 75, the nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity MVCHS must establish and maintain effective internal control over the Federal award that provides reasonable assurance MVCHS is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can been done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Internal controls over compliance do not appear to have been adequately implemented due to lack of training, oversight, or resources. Effect The Institute may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend that the organization: View of Responsible Officials MVCHS acknowledges the need to implement procedures to verify the suspension and debarment status of contractors prior to using federal funds. The Finance Department will develop a process to check for suspension and debarment prior to issuing a purchase order. This process will be completed by May 6, 2024. Carla Melendez, Chief Financial Officer will be responsible for developing and implementing this process. • follow its policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • include the required suspension and debarment clause in its contracts with contractors using federal funds.

(E) Significant Deficiency in Internal Control Over Compliance of Federal. Awards (F) Instance of noncompliance of Federal Awards Federal Agency: US Department of Health and Human Services Program Name: Health Centers Cluster Compliance Requirement: Procurement and Suspension and Debarment Questioned Costs: None Assistance Listing Number: 93.224, 93.527 Statement of Condition MVCHS did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. During our test work, it was noted that 4 out of 4 tests of internal control over compliance, MVCHS did not screen vendors for compliance with suspension and debarment requirements. Criteria MVCHS is required to verify that entities it plans to do business with are not excluded or disqualified under the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §75.303 Internal controls of 45 CFR Part 75, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to §75.327 general procurement standards of 45 CFR Part 75, the nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity MVCHS must establish and maintain effective internal control over the Federal award that provides reasonable assurance MVCHS is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can been done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Internal controls over compliance do not appear to have been adequately implemented due to lack of training, oversight, or resources. Effect The Institute may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend that the organization: View of Responsible Officials MVCHS acknowledges the need to implement procedures to verify the suspension and debarment status of contractors prior to using federal funds. The Finance Department will develop a process to check for suspension and debarment prior to issuing a purchase order. This process will be completed by May 6, 2024. Carla Melendez, Chief Financial Officer will be responsible for developing and implementing this process. • follow its policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • include the required suspension and debarment clause in its contracts with contractors using federal funds.