Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
2022-003 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? Assistance Listing No. 93.498U.S. Department of Health and Human ServicesCriteria or Specific Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342)Condition ? Within the Provider Relief Fund Reporting Portal for Period 1, the Organization reported other Provider Relief Fund (PRF) expenses and lost revenues calculated using option iii. The financial records utilized by management in the preparation of the Period 1 report contained a material error.Questioned Costs ? NoneContext ? The Period 1 PRF report was tested. The Organization calculated lost revenues based on the financial records available during the PRF reporting window; however, during the preparation of the Organization?s Missouri Medicaid cost report for the fiscal year ended May 31, 2021, which was after the PRF reporting window closed, it was determined that those financial records contained a material understatement of patient service revenue.Effect ? Lost revenues attributable to coronavirus, as reported in the Period 1 PRF report, were overstated.Cause ? The process of calculating the Missouri Medicaid cost report settlement is complex. Further, effective July 1, 2020, reimbursement for services to Missouri Medicaid beneficiaries enrolled in managed care changed, allowing the Organization to submit requests for interim payments throughout the year. Errors in these requests led the Organization to being entitled to more reimbursement through the Medicaid cost report than initially expected. Management?s valuation of patient service revenue at the time of preparing the Period 1 PRF report did not consider the errors in interim payment requests or the extent increased costs, which resulted in a material increase to patient service revenue and reduction to lost revenues attributable to coronavirus. This increase did not impact PRF payments used for lost revenues in Period 1.Identification as a repeat finding, if applicable ? Not a repeat finding.ReferenceNumber Finding2022-003 (Continued) Recommendation ? The Organization should strengthen controls surrounding the preparation of financial reports required to be prepared and submitted for federal grants to ensure they are prepared using complete and accurate financial information.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527U.S. Department of Health and Human Services6 H80CS00703, June 1, 2021 ? May 31, 20226 C14CS39926, September 1, 2020 ? August 31, 20236 H8FCS40544, April 1, 2021 ? March 31, 2023Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Procurement (45 CFR 75.329)Condition ? Procurement records were not maintained according to Uniform Guidance. The Organization did not follow its policy governing the verification that vendors of goods or services charged to federal awards are not suspended, debarred, or otherwise excluded.Questioned costs ? UnknownContext ? Procurements from each major program were tested.? Health Center Program Cluster ? A sample of three procurements totaling $749,531 were tested out of a population of ten procurements.? Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? A sample of two procurements totaling $85,031 were tested out of a population of eleven procurements.Samples were not, and were not intended to be, statistically valid. For the two vendors tested for the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program, the Organization?s procurement records were insufficient in accordance with the Organization?s procurement policy and Uniform Guidance. In all cases, documentation was not maintained of the verification that vendors selected for testing were not suspended, debarred, or otherwise excluded before entering into transactions with these vendors.Effect ? Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance.Cause ? The Organization did not comply with its procurement policy.Identification as a repeat finding, if applicable ? Yes, see Finding 2021-001.Recommendation ? The Organization should develop a process for maintaining documentation required by its procurement policy.Views of responsible officials and planned corrective actions ?
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Program ? Assistance Listing No. 93.912U.S. Department of Health and Human Services6 GA1RH33488, September 1, 2019 ? August 31, 20226 D60RH36761, August 1, 2020 ? July 31, 20216 D60RH36761, August 1, 2021 ? July 31, 20226 UK9RH43497, September 1, 2021 ? August 31, 2022Criteria or specific requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.430(i))Condition ? Charges to federal awards for salaries and wages were not based on records that accurately reflect the work performed for certain individuals.Questioned costs ? $39,196. Questioned costs were determined by identifying all employees in the grant expenditures listing whose salary or wages were partially charged to the grant for which the Organization could not support with time and attendance records. Questioned costs also include allocated fringe benefits at a 7 percent rate. Questioned costs by federal award identification number are:? 6 GA1RH33488 ? $6,193? 6 D60RH36761 ? $9,227? 6 UK9RH43497 ? $23,776Context ? The Organization charged salaries and wages to federal awards based on budget estimates. The standards for documentation of personnel expenses require records to support the distribution of each employee?s salary or wages among specific activities if, among others, the employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity. Budget estimates may be used for interim accounting purposes as long as:(1) the Organization has a system for establishing the estimates that produces reasonable approximations of the activity actually performed, (2) significant changes in the corresponding work activity are identified and entered into the records in a timely manner, and (3) the Organization?s system of internal controls includes processes to adjust the final amount charged to federal awards to reflect the work performed.Effect ? Charges to federal awards for salaries and wages for certain individuals do not comply with standards for documentation of personnel expenses as they were not supported by records reflecting the work performed.Cause ? The Organization does not have a system in place to accurately capture work performed when an employee works on more than one federal award, a federal award and a non-federal award, or an unallowable activity and a direct cost activity.Identification as a repeat finding, if applicable ? Not a repeat finding.Recommendation ? The Organization should maintain supporting documentation for its estimates of work to be performed by each position for each federal award. The Organization should develop a system to capture work activity by federal award and non-federal award and allowable activities and unallowable activities. The Organization should implement a policy to revisit budget estimates based on actual work activity to ensure the final amount charged to federal awards is accurate, allowable and properly allocated.Views of responsible officials and planned corrective actions ?We are working on getting a process set up to monitor actual time spent on grants in comparison to budgeted time. The salaries charged to the grants were based on budget time, and while significant time was incurred that would be allowable as a direct cost to the grant, the documentation to support that actual time spent was not there.
2022-003 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? Assistance Listing No. 93.498U.S. Department of Health and Human ServicesCriteria or Specific Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342)Condition ? Within the Provider Relief Fund Reporting Portal for Period 1, the Organization reported other Provider Relief Fund (PRF) expenses and lost revenues calculated using option iii. The financial records utilized by management in the preparation of the Period 1 report contained a material error.Questioned Costs ? NoneContext ? The Period 1 PRF report was tested. The Organization calculated lost revenues based on the financial records available during the PRF reporting window; however, during the preparation of the Organization?s Missouri Medicaid cost report for the fiscal year ended May 31, 2021, which was after the PRF reporting window closed, it was determined that those financial records contained a material understatement of patient service revenue.Effect ? Lost revenues attributable to coronavirus, as reported in the Period 1 PRF report, were overstated.Cause ? The process of calculating the Missouri Medicaid cost report settlement is complex. Further, effective July 1, 2020, reimbursement for services to Missouri Medicaid beneficiaries enrolled in managed care changed, allowing the Organization to submit requests for interim payments throughout the year. Errors in these requests led the Organization to being entitled to more reimbursement through the Medicaid cost report than initially expected. Management?s valuation of patient service revenue at the time of preparing the Period 1 PRF report did not consider the errors in interim payment requests or the extent increased costs, which resulted in a material increase to patient service revenue and reduction to lost revenues attributable to coronavirus. This increase did not impact PRF payments used for lost revenues in Period 1.Identification as a repeat finding, if applicable ? Not a repeat finding.ReferenceNumber Finding2022-003 (Continued) Recommendation ? The Organization should strengthen controls surrounding the preparation of financial reports required to be prepared and submitted for federal grants to ensure they are prepared using complete and accurate financial information.Views of responsible officials and planned corrective actions ?