Audit 309100

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor list. Views of responsible officials: There is no disagreement with the audit finding.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-003 – Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 assessed an incorrect sliding fee discount. Questioned costs: None. Context: The Organization assessed one of forty patient encounters selected for testing, the incorrect sliding fee discount. Cause: Unknown Effect: Patients are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-008. 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.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

2022-006 – Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: § 200.329 indicates that the non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Condition: There were two instances in which documentation was not available to support amounts included within reports submitted. These instances affected the Federal Financial Report and the UDS report. Questioned costs: None. Context: Documentation was not available to support the amount reported on line E, Federal share of expenditures, of the ARPA Federal Financial Report. In addition, there was no documentation to support two key lines items of the UDS report, Table 9E, Lines 1g and 1q, Column A. Cause: Management turnover Effect: Inaccurate reports could be file if there is no underlying documentation to support the amounts reported. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-07. Recommendation: We recommend that the Organization maintain supporting documentation for all reports required to be filed to the federal agency. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor 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 title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor list. Views of responsible officials: There is no disagreement with the audit finding.