Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-003 Cash Management – Federal Grants
Federal Programs: Department of Health and Human Services
Grants for Capital Development in Health Centers
Assistance Listing No. 93.526
Criteria: Cash Management, 45 CFR 75.305
Condition: During the year, the Organization made one draw of federal funds that was not disbursed in a timely manner for program expenditures. The Organization is required to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes.
Cause: The Organization made a draw of federal grant funds in advance of making the qualifying expenditures.
Effect: Although expenditures were made prior to December 31, 2023, the Organization did not minimize the time elapsing between transfer of funds from the United States Treasury and the disbursement for expenditures.
Questioned Costs: None reported.
Context/Sampling: The finding appears to be a systemic issue.
Repeat Finding from Prior Year: No
Recommendation: Efforts should be made to ensure advance draws of federal funds do not occur.
Views of Responsible Officials: The Organization understands the requirements to disburse federal funds in a timely manner. Procedures will be established to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes by the Organization.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-001 Sliding Fee Discounts
Federal Programs: Department of Health and Human Services
Health Center Program Cluster
CFDA 93.224 and 93.527
Criteria: Uniform Guidance, Special Tests & Provisions, Sliding Fee Discounts, 42 CFR, 56.303
Condition: Health centers that receive funding under the Health Center Program Cluster must prepare and apply a sliding fee discount so that the amounts owed for health center services by eligible patients are discounted based on the patient’s ability to pay. During compliance testing, it was determined that the Organization did not obtain and properly document all necessary elements required by the Organization’s policy.
Cause: There were deficiencies in internal controls over the Organization’s sliding fee program. For certain patient accounts that were tested as part of the audit, the Organization was unable to substantiate that proper documentation was obtained and that proper sliding fee discounts were applied to patient accounts in accordance with the Organization’s sliding fee scale.
Effect: Proper documentation was unavailable to substantiate that discounts were properly applied to patient accounts.
Questioned Costs: None
Context/Sampling: For 4 of 48 patients selected for testing, incorrect discounts were provided. Two patients received an incorrect discount; one patient received a discount who did not qualify for a discount; and one patient who qualified for a discount was not provided a discount. This sample was not, and was not intended to be, a statistically valid sample. The finding appears to be a systemic issue.
Repeat Finding from Prior Year: Yes
Recommendation: It is recommended that employees are properly trained to document and apply the sliding fee discounts in accordance with the Organization’s sliding fee policy. It is also recommended that sliding fee discounts are reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale.
Views of Responsible Officials: Management concurs. Efforts will be made to implement corrective actions as recommended above.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-002 Monthly time/activity reports not maintained for salaried employees
Federal Program Identification: U.S. Department of Health and Human Services
Health Center Cluster
CFDA 93.224 & 93.527
Criteria: Uniform Guidance Compliance Supplement, Grant Policy Statements, 45 CFR, 75.430
Condition: Time/activity reports (time sheets) are not maintained for salaried employees
Cause: The Organization’s policy does not require salaried employees to certify time and efforts that coincide with the Organization’s payroll cycle (at least on a monthly basis).
Effect: Failure to comply with federal requirements regarding personnel cost and time and effort could result in a reduction of grant funds.
Questioned Costs: None
Context/Sampling: A test of payroll disbursements revealed that monthly time and effort certifications for salaried employees were not maintained. The finding appears to be a systemic issue.
Recommendation: Procedures should be established to maintain time and effort certifications by all salaried employees. It is recommended that time and effort certifications be prepared no less than on a monthly basis and coincide with the Organization’s payroll cycle.
Views of Responsible Officials: Procedures will be established to ensure that salaried employees certify time and effort that coincides with the Organization’s payroll cycle.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024
Finding: 2023-003 Cash Management – Federal Grants
Federal Programs: Department of Health and Human Services
Grants for Capital Development in Health Centers
Assistance Listing No. 93.526
Criteria: Cash Management, 45 CFR 75.305
Condition: During the year, the Organization made one draw of federal funds that was not disbursed in a timely manner for program expenditures. The Organization is required to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes.
Cause: The Organization made a draw of federal grant funds in advance of making the qualifying expenditures.
Effect: Although expenditures were made prior to December 31, 2023, the Organization did not minimize the time elapsing between transfer of funds from the United States Treasury and the disbursement for expenditures.
Questioned Costs: None reported.
Context/Sampling: The finding appears to be a systemic issue.
Repeat Finding from Prior Year: No
Recommendation: Efforts should be made to ensure advance draws of federal funds do not occur.
Views of Responsible Officials: The Organization understands the requirements to disburse federal funds in a timely manner. Procedures will be established to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes by the Organization.
Contact Person: Jennifer Dittes, CEO
Anticipated Date of Completion: May 31, 2024