Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Infrastructure Support ? Assistance Listing No. 93.526 Assistance Listing Number: 93.526 Federal Award Identification Number: C8ECS44566-01 Award Periods: September 15, 2021 ? September 14, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.400 Policy guide (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. Condition: The Center has an on-going construction project as of June 30, 2022, and performed a drawdown of its federal award based on one-hundred percent of the incurred allowable costs of the project rather than what the grant agreement requires, which is that drawdowns occur in the same proportion as the grant is to the total project costs in the approved budget. Questioned Costs: None. Context: One (1) of one (1) transaction tested. Cause: Oversight. Effect: The Organization may draw down funding in a proportion greater than is allowed and for a project that does not get completed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for monitoring grant compliance, reinforce the important of reviewing all grant agreement provisions, and implement a system of processes and controls for tracking compliance with all specific grant terms and conditions. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.526 Federal Award Identification Number: C8ECS44566-01 Award Periods: September 15, 2021 ? September 14, 2024 Type of Finding: Compliance and material weakness in internal control over compliance Criteria: ? 200.458 Pre-award costs are those incurred prior to the effective date of the Federal award or subaward directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. If charged to the award, these costs must be charged to the initial budget period of the award, unless otherwise specified by the Federal awarding agency or pass-through entity. Condition: The Center received reimbursement from the federal grant for costs that were incurred prior to the period of performance, but were not pre-approved by the awarding agency. Questioned Costs: $83,934 Context: Five (5) of five (5) transactions tested. Cause: There was a miscommunication within the Center as to whether the costs were pre-approved. Effect: The Organization may allocate unallowable costs to the federal grant. Repeat Finding: No. Recommendation: Management should refine its current process and controls for determining what costs are considered allowable so that it's clear who makes this determination and is communicated timely to the appropriate departments. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00276-20; H80CS00276-21 Award Periods: June 1, 2021 ? May 31, 2022; June 1, 2022 ? May 31, 2023 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization had assessed four patients with the incorrect sliding fee discount; three patients were assessed a higher discount and one patient was assessed a lower discount based on their family size and income information that was documented. Questioned Costs: None. Context: Four (4) of forty (40) transaction tested. Cause: Patients? family size and income information was either not received or was not reviewed and updated within the Center?s billing system. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: The Center did not maintain proper documentation for determining the rationale of the procurement methodology that it applied. Questioned Costs: None. Context: Two (2) of seven (7) vendors tested. Cause: The Center did not create and maintain documentation for its rationale related to choosing the noncompetitive procurement method. Effect: The Center may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: No. Recommendation: Management should adhere to the Center?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS41001-01; C8ECS44566-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.214 Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Center inadvertently excluded two vendors from its routine comparison of the Organization's active vendors to the federal exclusions database. Questioned Costs: None. Context: Four (4) of seven (7) vendors tested. Cause: The Center?s current process for checking vendors for suspension and debarment did not include a process whereby it ensured all new vendors engaged during the year were first checked for suspension and debarment. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for performing the search for suspended and debarred vendors in the federal exclusions database to reemphasize the importance of this procedure. This could include performing a suspension and debarment check on all new vendors when they are initially set-up within the purchase system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Infrastructure Support ? Assistance Listing No. 93.526 Assistance Listing Number: 93.526 Federal Award Identification Number: C8ECS44566-01 Award Periods: September 15, 2021 ? September 14, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: ? 200.400 Policy guide (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. Condition: The Center has an on-going construction project as of June 30, 2022, and performed a drawdown of its federal award based on one-hundred percent of the incurred allowable costs of the project rather than what the grant agreement requires, which is that drawdowns occur in the same proportion as the grant is to the total project costs in the approved budget. Questioned Costs: None. Context: One (1) of one (1) transaction tested. Cause: Oversight. Effect: The Organization may draw down funding in a proportion greater than is allowed and for a project that does not get completed. Repeat Finding: No. Recommendation: Management should provide additional training to individuals responsible for monitoring grant compliance, reinforce the important of reviewing all grant agreement provisions, and implement a system of processes and controls for tracking compliance with all specific grant terms and conditions. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.526 Federal Award Identification Number: C8ECS44566-01 Award Periods: September 15, 2021 ? September 14, 2024 Type of Finding: Compliance and material weakness in internal control over compliance Criteria: ? 200.458 Pre-award costs are those incurred prior to the effective date of the Federal award or subaward directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. If charged to the award, these costs must be charged to the initial budget period of the award, unless otherwise specified by the Federal awarding agency or pass-through entity. Condition: The Center received reimbursement from the federal grant for costs that were incurred prior to the period of performance, but were not pre-approved by the awarding agency. Questioned Costs: $83,934 Context: Five (5) of five (5) transactions tested. Cause: There was a miscommunication within the Center as to whether the costs were pre-approved. Effect: The Organization may allocate unallowable costs to the federal grant. Repeat Finding: No. Recommendation: Management should refine its current process and controls for determining what costs are considered allowable so that it's clear who makes this determination and is communicated timely to the appropriate departments. Views of Responsible Officials: There is no disagreement with the audit finding.