FAC Explorer

Audit 318279

FY End
2023-11-30
Total Expended
$5.38M
Findings
8
Programs
6
Organization: Neighborhood Health Association of Toledo, Inc. (OH)
Year: 2023 Accepted: 2024-08-30
Auditor: Cla (clifton Larson Allen Llp)

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
485506 2023-001 Significant Deficiency Yes N
485507 2023-002 Significant Deficiency Yes I
485508 2023-002 Significant Deficiency Yes I
485509 2023-003 - Yes L
1061948 2023-001 Significant Deficiency Yes N
1061949 2023-002 Significant Deficiency Yes I
1061950 2023-002 Significant Deficiency Yes I
1061951 2023-003 - Yes L

Programs

ALN Program Spent Major Findings
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $4.49M Yes 3
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $371,894 Yes 1
93.498 Provider Relief Fund $53,659 - 0
14.218 Community Development Block Grants/entitlement Grants $51,426 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $45,402 - 0
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $40,539 - 0

Contacts

Name Title Type
GFJMVJX6KC93 Tyson Bouyack Auditee
4197207883 Diann Stretten Auditor
No contacts on file

Notes to SEFA

Title: PROVIDER RELIEF FUNDS Accounting Policies: NOTE 2 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. NOTE 1 BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards, which includes all federal grant activity of the Association, is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used, in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The Association has elected not to use the ten-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The Organization received $53,659 in DHHS Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution (Federal Assistance Listing #93.498) during the year ended November 30, 2022. The Organization incurred eligible expenditures and lost revenue and therefore recognized the revenue of $53,659 on the consolidated statement of activities and changes in net assets for the year ended November 30, 2022. However, the PRF expenditures were not recognized on the Schedule of Expenditures of Federal Awards for the fiscal year ended November 30, 2022, as the OMB Compliance Supplement of 2023. requires the federal expenditures to be excluded from the Schedule of Expenditures of Federal Awards (SEFA) until the applicable reporting period as outlined by DHHS. Amounts presented on the SEFA for the year ended November 30, 2023, of $53,659 were presented in revenue on the consolidated statement of activities and changes in net assets for the fiscal year ended November 30, 2022.

Finding Details

Finding 2023-001
Special Tests and Provisions Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific Requirement-Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients’ ability to pay. Condition-Context During a sample of 60 patient encounter visits; we noted seven encounter visits where the sliding fee adjustment applied to a patient’s account was applied at the incorrect amount per the Association’s sliding fee scale. Cause Due to the employee turnover within the front desk and the finance department, the Organization has had difficulty in training and assuring skilled intake staff are correctly applying the sliding fees. Effect or Potential Effect Applicants assessed are not charged according to the Association’s sliding fee scale and ability to pay. Questioned Costs None. Repeat Finding Yes, see finding 2022-002.Recommendation We recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is filed before applying a sliding fee discount to a patient account. In addition, continue with the system of monitoring that was established during fiscal year 2023 to review random samples of applications and sliding fees applied. Management Response We agreed with the above comment, and we are working with our intake and finance staff to ensure all documentation is maintained on file and scanned into the EMR system to maintain the required supporting documentation. During 2023 we have implemented a system of monitoring sliding fees applied to patient accounts.
Finding 2023-002
Suspension and Debarment Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) 93.526 Grants for Capital Development in Health Centers Type of Finding: Significant deficiency in internal control over compliance Specific Requirement-Criteria Nonfederal 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 - Context The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected five of ten parties selected for testing. The Association did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date and during 2023 new procedures were implemented to review for suspension and debarment. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat Finding Yes, see finding 2022-003. Recommendation We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Management Response We agreed with the above comment and the Association conducted training with the finance department during 2023 to ensure that all members are educated on the required policies for compliance. In addition, a third party vendor system was contracted with by the Association in 2023 to regularly run a utility to review their vendor listing for suspended and debarred entities.
Finding 2023-002
Suspension and Debarment Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) 93.526 Grants for Capital Development in Health Centers Type of Finding: Significant deficiency in internal control over compliance Specific Requirement-Criteria Nonfederal 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 - Context The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected five of ten parties selected for testing. The Association did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date and during 2023 new procedures were implemented to review for suspension and debarment. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat Finding Yes, see finding 2022-003. Recommendation We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Management Response We agreed with the above comment and the Association conducted training with the finance department during 2023 to ensure that all members are educated on the required policies for compliance. In addition, a third party vendor system was contracted with by the Association in 2023 to regularly run a utility to review their vendor listing for suspended and debarred entities.
Finding 2023-003
Reporting Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific Requirement - Criteria The Association is required to submit Federal Financial Reports (SF-425 FFR) on an annual and final basis for grant periods. Condition - Context In a sample of three reports, the following two, of the required Federal Financial Report (SF-425 FFR), were not submitted within the required time frame: Report PeriodDate ReportDate ReportReportEnd date DueSubmittedAnnual FFRMarch 31, 2023July 30, 2023September 1, 2023Annual FFRMarch 31, 2023July 30, 2023September 1, 2023 Cause Due to open positions in the finance department, untimely completion of internal financial reporting occurred during fiscal year 2021, 2022 and 2023, accordingly the financial records were being brought up to date to ensure accuracy in reporting on the FFR, resulting in late data to be available for reporting on the FFRs. During 2022, the Associate hired contract financial consultants to aid in the open positions and bring financial information up to date. Effect Noncompliance with the grant agreement requirement reporting due dates. Questioned Costs None. Repeat Finding Yes, see finding 2022-004 Recommendation We recommend that management instills a system on monitoring all reporting due dates and within the finance department to ensure all grant agreement required reporting is met. Management Response We agreed with the above comment and all reporting has been completed and up to date as of November 30, 2023.
Finding 2023-001
Special Tests and Provisions Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance and significant deficiency in internal control over compliance Specific Requirement-Criteria Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patients’ ability to pay. Condition-Context During a sample of 60 patient encounter visits; we noted seven encounter visits where the sliding fee adjustment applied to a patient’s account was applied at the incorrect amount per the Association’s sliding fee scale. Cause Due to the employee turnover within the front desk and the finance department, the Organization has had difficulty in training and assuring skilled intake staff are correctly applying the sliding fees. Effect or Potential Effect Applicants assessed are not charged according to the Association’s sliding fee scale and ability to pay. Questioned Costs None. Repeat Finding Yes, see finding 2022-002.Recommendation We recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is filed before applying a sliding fee discount to a patient account. In addition, continue with the system of monitoring that was established during fiscal year 2023 to review random samples of applications and sliding fees applied. Management Response We agreed with the above comment, and we are working with our intake and finance staff to ensure all documentation is maintained on file and scanned into the EMR system to maintain the required supporting documentation. During 2023 we have implemented a system of monitoring sliding fees applied to patient accounts.
Finding 2023-002
Suspension and Debarment Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) 93.526 Grants for Capital Development in Health Centers Type of Finding: Significant deficiency in internal control over compliance Specific Requirement-Criteria Nonfederal 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 - Context The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected five of ten parties selected for testing. The Association did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date and during 2023 new procedures were implemented to review for suspension and debarment. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat Finding Yes, see finding 2022-003. Recommendation We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Management Response We agreed with the above comment and the Association conducted training with the finance department during 2023 to ensure that all members are educated on the required policies for compliance. In addition, a third party vendor system was contracted with by the Association in 2023 to regularly run a utility to review their vendor listing for suspended and debarred entities.
Finding 2023-002
Suspension and Debarment Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224/93.527 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) 93.526 Grants for Capital Development in Health Centers Type of Finding: Significant deficiency in internal control over compliance Specific Requirement-Criteria Nonfederal 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 - Context The Association did not verify that certain employees and vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal programs or activities before entering into transactions with them. The condition affected five of ten parties selected for testing. The Association did ultimately verify that the contracted parties were not suspended or debarred; however, it was after initially contracting with them. Cause Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date and during 2023 new procedures were implemented to review for suspension and debarment. Effect Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association. Questioned Costs None. Repeat Finding Yes, see finding 2022-003. Recommendation We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Management Response We agreed with the above comment and the Association conducted training with the finance department during 2023 to ensure that all members are educated on the required policies for compliance. In addition, a third party vendor system was contracted with by the Association in 2023 to regularly run a utility to review their vendor listing for suspended and debarred entities.
Finding 2023-003
Reporting Federal Program and Specific Federal Award U.S. Department of Health and Human Services (HHS) 93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Type of Finding: Compliance Specific Requirement - Criteria The Association is required to submit Federal Financial Reports (SF-425 FFR) on an annual and final basis for grant periods. Condition - Context In a sample of three reports, the following two, of the required Federal Financial Report (SF-425 FFR), were not submitted within the required time frame: Report PeriodDate ReportDate ReportReportEnd date DueSubmittedAnnual FFRMarch 31, 2023July 30, 2023September 1, 2023Annual FFRMarch 31, 2023July 30, 2023September 1, 2023 Cause Due to open positions in the finance department, untimely completion of internal financial reporting occurred during fiscal year 2021, 2022 and 2023, accordingly the financial records were being brought up to date to ensure accuracy in reporting on the FFR, resulting in late data to be available for reporting on the FFRs. During 2022, the Associate hired contract financial consultants to aid in the open positions and bring financial information up to date. Effect Noncompliance with the grant agreement requirement reporting due dates. Questioned Costs None. Repeat Finding Yes, see finding 2022-004 Recommendation We recommend that management instills a system on monitoring all reporting due dates and within the finance department to ensure all grant agreement required reporting is met. Management Response We agreed with the above comment and all reporting has been completed and up to date as of November 30, 2023.