Audit 322303

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-004 Allowable Costs/Cost Principles Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E sets for the specific cost principles to be followed when expending federal funds. Condition The Organization charged expenditures that were not necessary and reasonable for performance of the award to the federal grants. The Organization charged salaries in excess of the federal limits to grants. The Organization claimed the same expenditure for reimbursement under multiple grants. The Organization did not maintain sufficient supporting records for all of the expenditures reimbursed with federal awards. This finding appears to be a systemic problem Cause The Organization’s internal controls did not include proper review of transactions charged to federal programs to ensure that the goods or services received were necessary for the performance of the award, and that the transactions were supported by the appropriate documentation. In addition, expenditures were not properly tracked by grant, which allowed for the same costs to be charged to multiple awards. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $534,222 Context In a sample of sixty invoices tested, eight were found to be for expenditures that were not consistent with the allowable cost principles. We identified $283,128 of expenditures that were not necessary for the performance of the award due to the goods or services not yet being provided. In addition, we identified $56,685 of expenditures for which the Organization could not provide supporting documentation, $152,678 of salaries that were charged to multiple programs and $38,021 of expenditures that were either recorded multiple times or were already charged to another program. In addition, one employee had $3,710 of wages in excess of the federal thresholds charged to federal programs. Recommendation We recommend the Organization implement a system to track and document all expenditures of federal awards in the financial management system and that supporting documentation for all federal expenditures, whether payroll or procurement transactions, be maintained. In addition, we recommend the Organization implement controls sufficient to monitor the system to ensure it is properly designed and effective. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-005 Period of Performance Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.403(h) requires that costs be incurred in the approved budget period for the applicable awards and Title 2 CFR 200.403(e) requires that those costs be determined according to generally accepted accounting principles (GAAP). Condition The Organization’s federal expenditures includes costs for goods and/or services outside of the approved budget periods for the awards. Cause The Organization’s internal controls over compliance did not include consideration of when the goods were received or services were performed compared to the budget periods for the awards. Lack of understanding of GAAP and the requirements of accrual basis accounting allowed expenditures outside of the applicable budget periods to be approved and claimed as current federal expenditures based solely on management’s decision to pay for the expenditure in the current year. Effect The Organization may allocate unallowable costs to the federal awards. Questioned Costs $321,877 (of which $283,128 was previously reported in finding 2024-004 above) Context In a sample of sixty invoices, we noted eight included expenditures for goods or services that were not provided in the current budget period. $283,129 of expenditures charged to the program were for goods or services related to future budget periods. $38,748 of expenditures charged to the program were for goods or services related to previous budget periods. Recommendation We recommend management personnel authorized to approve expenditures of federal awards be limited to those who have a basic understanding of GAAP and the relationship between the accrual basis of accounting and the period of performance requirements. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-006 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used only in certain circumstances as allowed for in 2 CFR 200.320(c). Condition The Organization’s procurement policy allows the Board to authorize noncompetitive procurement for certain types expenditures which are outside the circumstances allowing for noncompetitive bids under 2 CFR 200.320(c). In addition, the Organization did not follow its documented procurement policy. Cause The Organization’s procurement policy was not compared with the federal regulations when it was developed. Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $514,086 (of which $318,272 was previously reported in findings 2024-004 and 2024-005 above) Context In a sample of sixty invoices, we noted fourteen with issues related to the procurement process. Four of these related to the Organization’s procurement policy being non-compliant with the federal requirements. Two of these were due to the Organization not following their established procurement policy and eight were due to the lack of appropriate documentation of the competitive bids. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-007 Reporting (repeat of finding 2023-003) Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Based on the standards of documentation of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D requires the Organization to retain adequate records and other supporting documentation for reports submitted to awarding agencies under the compliance requirements for reporting. Condition The Organization did not maintain sufficient supporting records for the information reported in its calendar year 2023 Uniform Data System (UDS) report. This finding appears to be a systemic problem. Cause The Organization’s internal controls over compliance did not include adequate controls over the retention of supporting documentation for UDS reports submitted to awarding agencies. Effect The Organization submitted UDS reports for federal awards that may lack supporting documentation. Amounts reported may not be correct. Questioned Costs None identified Context Amounts reported in Table 8A and Table 9E did not agree to the supporting documentation. Recommendation We recommend the Organization maintain documentation supporting reports filed with awarding agencies. If changes to the reported amounts are made, the supporting documentation should be updated and the reason for the change should be documented. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2024-008 Cash Management Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197 Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Condition Cash draws were made without support of approved documentation. Supporting documentation for other draws included invoices for expenditures that were dated several months after the draw was made. This finding appears to be a systemic problem Cause The Organization’s internal controls over cash management and PMS draws does not include procedures for non-payroll expenditures. As a result, draws were made without supporting documentation. In addition, the Organization did not always maintain documentation of the payroll calculations supporting draws, as required by company policy. Effect The Organization may not have minimized the timing between draws from the PMS and the related payments for expenditures incurred as required. Questioned Costs Indeterminable. Context Out of thirteen draws tested, the Organization was not able to provide supporting documentation for one draw and support for two additional draws included expenses that were not incurred within a reasonable time after the draw. Recommendation We recommend the Organization implement controls requiring all draws from the Payment Management System (PMS) to be based on detailed reports of expenditures claimed for reimbursement and retain this documentation along with the supporting invoices and payroll reports supporting the expenditures. In addition, we recommend that the listing of expenditures be reviewed by qualified personnel to ensure that the expenditures claimed are allowable and cash payments for the expenditures are made before the date of the draw or within a reasonable time after the draw. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.