Audit 310507

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-006—Allowable Costs Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 2 CFR Part 225, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, non-Federal entities receiving federal awards should establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: For two of 25 payroll transactions tested, there was no support for the approved pay rate of the employee. For nine of 25 nonpayroll transactions tested, there was no evidence available supporting that the items ordered had been received by the program/location for which they were ordered. Questioned Costs: Undeterminable for the payroll transactions tested and $46,643 for the nonpayroll transactions tested. Context: Two of 25 payroll transactions tested and nine of 25 nonpayroll transactions tested were not adequately documented. Cause: FCCH is not following its approved policies and procedures over personnel records and accounts payable. Additionally, FCCH has not developed policies and procedures requiring documentation that goods purchased have been received by the program/location prior to payments being approved and remitted to vendors. Effect: FCCH may not be able to demonstrate that some costs charged to federal programs are allowable. Auditor’s Recommendations: FCCH should implement its approved policies and procedures to ensure that amounts charged to federal programs are allowable and properly documented. Additionally, FCCH should consider updating its policies and procedures to require documentation that goods purchased have been received by the program/location prior to payments being remitted to vendors. Management’s Response: FCCH management shall promote accountability for following approved policies and procedures over employee records and accounts payable. Receiving policies and processes, including documentation for receiving inventory and equipment, should be developed and then implemented. All involved personnel should be trained in the new policies.

2021-007—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For two of 40 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed during the clinic visit. One claim was billed to a third-party payer, and one claim was billed to the patient under FCCH’s sliding fee discount program (SFDP). Questioned Costs: None Context: Two of 40 medical claims tested. Cause: FCCH experienced significant turnover in key positions in the billing department, including the Revenue Cycle Manager, and approved policies and procedures were not followed. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors. Management’s Response: FCCH Management shall ensure adherence to established policies and procedures. Charges shall follow the schedule of fees and services, and discount programs shall be administered accurately so that compliance with 42 CFR Part 51c.303(f) and Sliding Fee Discount policies are maintained. FCCH shall also perform a review of its medical claims billed, determine the prevalence of errors, and educate staff to improve accuracy.

2021-008—Reporting Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: Federal Financial Reports (SF-425) are required to be submitted to the granting agency according to the Notice of Awards for these programs. Condition: Three of six SF-425 reports tested were submitted past the deadline after the end of each period. Questioned Costs: None Context: Three of six SF-425 reports tested for these awards. Cause: FCCH experienced turnover in the accounting department in key positions in recent years and, as a result, approved policies and procedures were not followed. Additionally, program personnel did not review and approve the reports for submission in a timely manner. Effect: FCCH is not in compliance with reporting requirements for these awards. Auditor’s Recommendations: FCCH should implement its Grants/Contracts Submission and Management Policies and Procedures to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: FCCH shall implement its Grants/Contracts Submission and Management Policies and Procedures and educate staff to ensure all program reports are properly completed and submitted by the required due dates. Access to reporting portals shall be granted to and maintained by appropriate personnel so that turnover does not impair compliance.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-006—Allowable Costs Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 2 CFR Part 225, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, non-Federal entities receiving federal awards should establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: For two of 25 payroll transactions tested, there was no support for the approved pay rate of the employee. For nine of 25 nonpayroll transactions tested, there was no evidence available supporting that the items ordered had been received by the program/location for which they were ordered. Questioned Costs: Undeterminable for the payroll transactions tested and $46,643 for the nonpayroll transactions tested. Context: Two of 25 payroll transactions tested and nine of 25 nonpayroll transactions tested were not adequately documented. Cause: FCCH is not following its approved policies and procedures over personnel records and accounts payable. Additionally, FCCH has not developed policies and procedures requiring documentation that goods purchased have been received by the program/location prior to payments being approved and remitted to vendors. Effect: FCCH may not be able to demonstrate that some costs charged to federal programs are allowable. Auditor’s Recommendations: FCCH should implement its approved policies and procedures to ensure that amounts charged to federal programs are allowable and properly documented. Additionally, FCCH should consider updating its policies and procedures to require documentation that goods purchased have been received by the program/location prior to payments being remitted to vendors. Management’s Response: FCCH management shall promote accountability for following approved policies and procedures over employee records and accounts payable. Receiving policies and processes, including documentation for receiving inventory and equipment, should be developed and then implemented. All involved personnel should be trained in the new policies.

2021-007—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For two of 40 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed during the clinic visit. One claim was billed to a third-party payer, and one claim was billed to the patient under FCCH’s sliding fee discount program (SFDP). Questioned Costs: None Context: Two of 40 medical claims tested. Cause: FCCH experienced significant turnover in key positions in the billing department, including the Revenue Cycle Manager, and approved policies and procedures were not followed. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors. Management’s Response: FCCH Management shall ensure adherence to established policies and procedures. Charges shall follow the schedule of fees and services, and discount programs shall be administered accurately so that compliance with 42 CFR Part 51c.303(f) and Sliding Fee Discount policies are maintained. FCCH shall also perform a review of its medical claims billed, determine the prevalence of errors, and educate staff to improve accuracy.

2021-008—Reporting Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: Federal Financial Reports (SF-425) are required to be submitted to the granting agency according to the Notice of Awards for these programs. Condition: Three of six SF-425 reports tested were submitted past the deadline after the end of each period. Questioned Costs: None Context: Three of six SF-425 reports tested for these awards. Cause: FCCH experienced turnover in the accounting department in key positions in recent years and, as a result, approved policies and procedures were not followed. Additionally, program personnel did not review and approve the reports for submission in a timely manner. Effect: FCCH is not in compliance with reporting requirements for these awards. Auditor’s Recommendations: FCCH should implement its Grants/Contracts Submission and Management Policies and Procedures to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: FCCH shall implement its Grants/Contracts Submission and Management Policies and Procedures and educate staff to ensure all program reports are properly completed and submitted by the required due dates. Access to reporting portals shall be granted to and maintained by appropriate personnel so that turnover does not impair compliance.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-006—Allowable Costs Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 2 CFR Part 225, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, non-Federal entities receiving federal awards should establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: For two of 25 payroll transactions tested, there was no support for the approved pay rate of the employee. For nine of 25 nonpayroll transactions tested, there was no evidence available supporting that the items ordered had been received by the program/location for which they were ordered. Questioned Costs: Undeterminable for the payroll transactions tested and $46,643 for the nonpayroll transactions tested. Context: Two of 25 payroll transactions tested and nine of 25 nonpayroll transactions tested were not adequately documented. Cause: FCCH is not following its approved policies and procedures over personnel records and accounts payable. Additionally, FCCH has not developed policies and procedures requiring documentation that goods purchased have been received by the program/location prior to payments being approved and remitted to vendors. Effect: FCCH may not be able to demonstrate that some costs charged to federal programs are allowable. Auditor’s Recommendations: FCCH should implement its approved policies and procedures to ensure that amounts charged to federal programs are allowable and properly documented. Additionally, FCCH should consider updating its policies and procedures to require documentation that goods purchased have been received by the program/location prior to payments being remitted to vendors. Management’s Response: FCCH management shall promote accountability for following approved policies and procedures over employee records and accounts payable. Receiving policies and processes, including documentation for receiving inventory and equipment, should be developed and then implemented. All involved personnel should be trained in the new policies.

2021-007—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For two of 40 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed during the clinic visit. One claim was billed to a third-party payer, and one claim was billed to the patient under FCCH’s sliding fee discount program (SFDP). Questioned Costs: None Context: Two of 40 medical claims tested. Cause: FCCH experienced significant turnover in key positions in the billing department, including the Revenue Cycle Manager, and approved policies and procedures were not followed. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors. Management’s Response: FCCH Management shall ensure adherence to established policies and procedures. Charges shall follow the schedule of fees and services, and discount programs shall be administered accurately so that compliance with 42 CFR Part 51c.303(f) and Sliding Fee Discount policies are maintained. FCCH shall also perform a review of its medical claims billed, determine the prevalence of errors, and educate staff to improve accuracy.

2021-008—Reporting Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: Federal Financial Reports (SF-425) are required to be submitted to the granting agency according to the Notice of Awards for these programs. Condition: Three of six SF-425 reports tested were submitted past the deadline after the end of each period. Questioned Costs: None Context: Three of six SF-425 reports tested for these awards. Cause: FCCH experienced turnover in the accounting department in key positions in recent years and, as a result, approved policies and procedures were not followed. Additionally, program personnel did not review and approve the reports for submission in a timely manner. Effect: FCCH is not in compliance with reporting requirements for these awards. Auditor’s Recommendations: FCCH should implement its Grants/Contracts Submission and Management Policies and Procedures to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: FCCH shall implement its Grants/Contracts Submission and Management Policies and Procedures and educate staff to ensure all program reports are properly completed and submitted by the required due dates. Access to reporting portals shall be granted to and maintained by appropriate personnel so that turnover does not impair compliance.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-006—Allowable Costs Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 2 CFR Part 225, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, non-Federal entities receiving federal awards should establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: For two of 25 payroll transactions tested, there was no support for the approved pay rate of the employee. For nine of 25 nonpayroll transactions tested, there was no evidence available supporting that the items ordered had been received by the program/location for which they were ordered. Questioned Costs: Undeterminable for the payroll transactions tested and $46,643 for the nonpayroll transactions tested. Context: Two of 25 payroll transactions tested and nine of 25 nonpayroll transactions tested were not adequately documented. Cause: FCCH is not following its approved policies and procedures over personnel records and accounts payable. Additionally, FCCH has not developed policies and procedures requiring documentation that goods purchased have been received by the program/location prior to payments being approved and remitted to vendors. Effect: FCCH may not be able to demonstrate that some costs charged to federal programs are allowable. Auditor’s Recommendations: FCCH should implement its approved policies and procedures to ensure that amounts charged to federal programs are allowable and properly documented. Additionally, FCCH should consider updating its policies and procedures to require documentation that goods purchased have been received by the program/location prior to payments being remitted to vendors. Management’s Response: FCCH management shall promote accountability for following approved policies and procedures over employee records and accounts payable. Receiving policies and processes, including documentation for receiving inventory and equipment, should be developed and then implemented. All involved personnel should be trained in the new policies.

2021-007—Special Tests and Provisions—Sliding Fee Discount Program Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8DCS36371 (4/1/2020–3/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: According to 42 CFR Part 51c.303(f) and FCCH’s Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures, a community health center must have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay, provided that such schedule of discounts shall provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition: For two of 40 medical claims tested, the amount billed did not agree to FCCH’s fee schedule for the procedures performed during the clinic visit. One claim was billed to a third-party payer, and one claim was billed to the patient under FCCH’s sliding fee discount program (SFDP). Questioned Costs: None Context: Two of 40 medical claims tested. Cause: FCCH experienced significant turnover in key positions in the billing department, including the Revenue Cycle Manager, and approved policies and procedures were not followed. Effect: FCCH is not in compliance with 42 CFR Part 51c.303(f). Additionally, FCCH is not in compliance with its Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Auditor’s Recommendations: FCCH should implement its established policies and procedures which require adherence to the approved schedule of fees for services and discounts. FCCH should also consider performing its own review of medical claims billed to determine the prevalence of these errors. Management’s Response: FCCH Management shall ensure adherence to established policies and procedures. Charges shall follow the schedule of fees and services, and discount programs shall be administered accurately so that compliance with 42 CFR Part 51c.303(f) and Sliding Fee Discount policies are maintained. FCCH shall also perform a review of its medical claims billed, determine the prevalence of errors, and educate staff to improve accuracy.

2021-008—Reporting Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Cluster Assistance Listing Number (ALN): 93.224, 93.527 Award number and year: H80C00202 (1/1/2021–12/31/2021) H8ECS37778 (5/1/2020–4/30/2021) H8F40603 (4/1/2021–3/31/2023) Criteria: Federal Financial Reports (SF-425) are required to be submitted to the granting agency according to the Notice of Awards for these programs. Condition: Three of six SF-425 reports tested were submitted past the deadline after the end of each period. Questioned Costs: None Context: Three of six SF-425 reports tested for these awards. Cause: FCCH experienced turnover in the accounting department in key positions in recent years and, as a result, approved policies and procedures were not followed. Additionally, program personnel did not review and approve the reports for submission in a timely manner. Effect: FCCH is not in compliance with reporting requirements for these awards. Auditor’s Recommendations: FCCH should implement its Grants/Contracts Submission and Management Policies and Procedures to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: FCCH shall implement its Grants/Contracts Submission and Management Policies and Procedures and educate staff to ensure all program reports are properly completed and submitted by the required due dates. Access to reporting portals shall be granted to and maintained by appropriate personnel so that turnover does not impair compliance.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.

2021-009—Late Audit Report Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award number and year: All Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (September 30, 2022). Condition: FCCH’s 2021 single audit reporting package was not submitted by the due date of September 30, 2022. Questioned Costs: None Context: N/A Cause: FCCH experienced turnover in the accounting department in key positions in recent years, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: FCCH was unable to completely reconcile certain general ledger accounts timely, which resulted in the audit not being completed within the reporting deadline. Auditor’s Recommendations: FCCH should implement its approved policies and procedures and complete the year-end account reconciliations in a timely manner to ensure the timely completion of the audit and submission of the single audit reporting package. Management’s Response: FCCH leadership shall ensure accountability for completing audits and submitting reports in a timely manner. Now that vacant positions in the accounting department have been filled, reconciliations are being caught up as efficiently as possible so that delinquent audits can also be conducted and concluded.