Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 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: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and incorrectly calculated or applied the sliding fee scale policy based on their family size and annual income.
Questioned costs: None.
Context: This condition occurred in twenty-six (26) of forty (40) transactions selected for testing.
Cause: Unknown.
Effect: Patients may not be assessed are not charged according to the Organization's sliding fee scale and their ability to pay.
Repeat Finding: Yes, prior year finding 2021-005.
Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 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: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and incorrectly calculated or applied the sliding fee scale policy based on their family size and annual income.
Questioned costs: None.
Context: This condition occurred in twenty-six (26) of forty (40) transactions selected for testing.
Cause: Unknown.
Effect: Patients may not be assessed are not charged according to the Organization's sliding fee scale and their ability to pay.
Repeat Finding: Yes, prior year finding 2021-005.
Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) 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. 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).
Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred.
Questioned costs: None.
Context: This condition occurred in three (3) of five (5) transactions selected for testing.
Cause: Turnover in key positions within the finance department.
Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet.
Repeat Finding: Yes, prior year finding 2021-004.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) 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. 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).
Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred.
Questioned costs: None.
Context: This condition occurred in three (3) of five (5) transactions selected for testing.
Cause: Turnover in key positions within the finance department.
Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet.
Repeat Finding: Yes, prior year finding 2021-004.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance
Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition: The Organization allocated payroll costs in a manner inconsistent with the personnel activity reports provided for the applicable employees and time periods selected for testing.
Questioned Costs: Unknown
Context: This condition occurred in four (4) of the forty (40) allowable cost transactions selected for testing within the health centers cluster major program, and represented three (3) different employees.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not consistently allocate payroll costs based on the personnel activity reports created.
Cause: Turnover within the finance department contributed to needing to reallocate certain payroll costs.
Repeat Finding: No.
Recommendation: We recommend that the Organization allocated payroll costs to grants in a manner that is consistent with the documentation contained within the personnel activity reports.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance
Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition: The Organization allocated payroll costs in a manner inconsistent with the personnel activity reports provided for the applicable employees and time periods selected for testing.
Questioned Costs: Unknown
Context: This condition occurred in four (4) of the forty (40) allowable cost transactions selected for testing within the health centers cluster major program, and represented three (3) different employees.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not consistently allocate payroll costs based on the personnel activity reports created.
Cause: Turnover within the finance department contributed to needing to reallocate certain payroll costs.
Repeat Finding: No.
Recommendation: We recommend that the Organization allocated payroll costs to grants in a manner that is consistent with the documentation contained within the personnel activity reports.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 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: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and incorrectly calculated or applied the sliding fee scale policy based on their family size and annual income.
Questioned costs: None.
Context: This condition occurred in twenty-six (26) of forty (40) transactions selected for testing.
Cause: Unknown.
Effect: Patients may not be assessed are not charged according to the Organization's sliding fee scale and their ability to pay.
Repeat Finding: Yes, prior year finding 2021-005.
Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 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: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and incorrectly calculated or applied the sliding fee scale policy based on their family size and annual income.
Questioned costs: None.
Context: This condition occurred in twenty-six (26) of forty (40) transactions selected for testing.
Cause: Unknown.
Effect: Patients may not be assessed are not charged according to the Organization's sliding fee scale and their ability to pay.
Repeat Finding: Yes, prior year finding 2021-005.
Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) 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. 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).
Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred.
Questioned costs: None.
Context: This condition occurred in three (3) of five (5) transactions selected for testing.
Cause: Turnover in key positions within the finance department.
Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet.
Repeat Finding: Yes, prior year finding 2021-004.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) 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. 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).
Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred.
Questioned costs: None.
Context: This condition occurred in three (3) of five (5) transactions selected for testing.
Cause: Turnover in key positions within the finance department.
Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet.
Repeat Finding: Yes, prior year finding 2021-004.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance
Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition: The Organization allocated payroll costs in a manner inconsistent with the personnel activity reports provided for the applicable employees and time periods selected for testing.
Questioned Costs: Unknown
Context: This condition occurred in four (4) of the forty (40) allowable cost transactions selected for testing within the health centers cluster major program, and represented three (3) different employees.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not consistently allocate payroll costs based on the personnel activity reports created.
Cause: Turnover within the finance department contributed to needing to reallocate certain payroll costs.
Repeat Finding: No.
Recommendation: We recommend that the Organization allocated payroll costs to grants in a manner that is consistent with the documentation contained within the personnel activity reports.
Views of responsible officials: There is no disagreement with this finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance
Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition: The Organization allocated payroll costs in a manner inconsistent with the personnel activity reports provided for the applicable employees and time periods selected for testing.
Questioned Costs: Unknown
Context: This condition occurred in four (4) of the forty (40) allowable cost transactions selected for testing within the health centers cluster major program, and represented three (3) different employees.
Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not consistently allocate payroll costs based on the personnel activity reports created.
Cause: Turnover within the finance department contributed to needing to reallocate certain payroll costs.
Repeat Finding: No.
Recommendation: We recommend that the Organization allocated payroll costs to grants in a manner that is consistent with the documentation contained within the personnel activity reports.
Views of responsible officials: There is no disagreement with this finding.