Audit 326910

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-003 Procurement, Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement The regulations in 2 CFR Part 180 restrict contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participant in Federal programs or activities. Procurement policies should be established to ensure documentation is retained to verify a check was done of the Governmentwide System for Award Management Exclusions – (SAM Exclusions) prior to awarding of contracts that will be funded with federal awards. Condition Evidence was not retained in procurement documentation to support confirmation of contractor status in SAM Exclusions as an entity not subject to suspension or debarment. Cause The Association’s policies over procurement were not designed appropriately to retain evidence of SAM Exclusions search suspension and debarment review for all contracts funded with federal awards. Effect or Potential Effect Federal funds could be disbursed to suspended or debarred entities. Questioned costs Not applicable. Context Procurement testing identified a total of 1 out of 1 contracts that did not have support that the SAM Exclusions search was conducted. A contemporaneous search of SAM Exclusions did not identify these vendors as excluded. Identification as a repeat finding Not a repeat finding. Recommendation A policy should be established and enforced to ensure that evidence of the SAM Exclusions search is retained. Staff should conduct self-review of procurement files for contracts awarded in prior years if it is known that the contract will be funded with a federal award to ensure that the SAM Exclusions search is performed prior to the expenditures of those funds and included in the procurement file. Views of responsible officials Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place.

Finding 2023-003 Procurement, Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement The regulations in 2 CFR Part 180 restrict contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participant in Federal programs or activities. Procurement policies should be established to ensure documentation is retained to verify a check was done of the Governmentwide System for Award Management Exclusions – (SAM Exclusions) prior to awarding of contracts that will be funded with federal awards. Condition Evidence was not retained in procurement documentation to support confirmation of contractor status in SAM Exclusions as an entity not subject to suspension or debarment. Cause The Association’s policies over procurement were not designed appropriately to retain evidence of SAM Exclusions search suspension and debarment review for all contracts funded with federal awards. Effect or Potential Effect Federal funds could be disbursed to suspended or debarred entities. Questioned costs Not applicable. Context Procurement testing identified a total of 1 out of 1 contracts that did not have support that the SAM Exclusions search was conducted. A contemporaneous search of SAM Exclusions did not identify these vendors as excluded. Identification as a repeat finding Not a repeat finding. Recommendation A policy should be established and enforced to ensure that evidence of the SAM Exclusions search is retained. Staff should conduct self-review of procurement files for contracts awarded in prior years if it is known that the contract will be funded with a federal award to ensure that the SAM Exclusions search is performed prior to the expenditures of those funds and included in the procurement file. Views of responsible officials Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place.

Finding 2023-004 Special Tests and Provisions - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 Health Center Program Cluster – Health Center Program/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement 42 CFR 51c.303 sets forth that community health centers are to have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay. Condition There were two patients who received discounts for sliding fee scale adjustments where there was not an approved application on file for the period in which they received services to document their ability to pay. Cause The Association's controls over retention and review of sliding fee scale applications for dental-related charges were insufficient. Effect or Potential Effect The Association is not compliant with 42 CFR 51c.303. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context There were two exceptions in the amount of $504 out of 29 items and $5,148 tested related to the Dentrix system adjustments. There were no exceptions to the 12 items and $2,164.33 tested for Cerner charges. Two additional items selected (totaling $206) from Dentrix were tested with no exception. Identification as a repeat finding Not a repeat finding. Recommendation Management should review existing processes and controls to ensure applications that document the patient’s ability to pay are retained and approved prior to applying any adjustments. Views of responsible officials Management concurs with this finding. Management plans to review adjustments to patient revenue on a quarterly basis.

Finding 2023-004 Special Tests and Provisions - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 Health Center Program Cluster – Health Center Program/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement 42 CFR 51c.303 sets forth that community health centers are to have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay. Condition There were two patients who received discounts for sliding fee scale adjustments where there was not an approved application on file for the period in which they received services to document their ability to pay. Cause The Association's controls over retention and review of sliding fee scale applications for dental-related charges were insufficient. Effect or Potential Effect The Association is not compliant with 42 CFR 51c.303. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context There were two exceptions in the amount of $504 out of 29 items and $5,148 tested related to the Dentrix system adjustments. There were no exceptions to the 12 items and $2,164.33 tested for Cerner charges. Two additional items selected (totaling $206) from Dentrix were tested with no exception. Identification as a repeat finding Not a repeat finding. Recommendation Management should review existing processes and controls to ensure applications that document the patient’s ability to pay are retained and approved prior to applying any adjustments. Views of responsible officials Management concurs with this finding. Management plans to review adjustments to patient revenue on a quarterly basis.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-005 Reporting Deadline for Federal Single Audit - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Assistance Listing Numbers (ALN) and Program Name Department of Health and Human Services and Alaska Native Tribal Health Consortium Finding 2023-005 is applicable to all grant awards issued for the following major programs: 93.210 - Tribal Self Governance Program: IHS Compacts/ Funding Agreements 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program 93.671 - Family Violence Prevention and Services/ Domestic Violence Shelter and Supportive Services Criteria or Specific Requirement 2 CFR 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit, and any extensions granted by the Office of Management and Budget. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2023. Cause The Association did not have controls in place to ensure the audit was completed timely so that the reporting package could be submitted to the FAC within the required timeframe. Effect or Potential Effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context This is a condition identified per review of the Association 's compliance with the specified requirements. Identification as a repeat finding Not a repeat finding. Recommendation We recommend the Association to establish controls to ensure the audit is completed timely and the reporting package is submitted to the FAC within the required timeframe. Views of responsible officials Management concurs with this finding. Specifically, the Association will strive to establish systems and controls to ensure the audit is completed timely and the reporting package is submitted within the required timeframes.

Finding 2023-003 Procurement, Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement The regulations in 2 CFR Part 180 restrict contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participant in Federal programs or activities. Procurement policies should be established to ensure documentation is retained to verify a check was done of the Governmentwide System for Award Management Exclusions – (SAM Exclusions) prior to awarding of contracts that will be funded with federal awards. Condition Evidence was not retained in procurement documentation to support confirmation of contractor status in SAM Exclusions as an entity not subject to suspension or debarment. Cause The Association’s policies over procurement were not designed appropriately to retain evidence of SAM Exclusions search suspension and debarment review for all contracts funded with federal awards. Effect or Potential Effect Federal funds could be disbursed to suspended or debarred entities. Questioned costs Not applicable. Context Procurement testing identified a total of 1 out of 1 contracts that did not have support that the SAM Exclusions search was conducted. A contemporaneous search of SAM Exclusions did not identify these vendors as excluded. Identification as a repeat finding Not a repeat finding. Recommendation A policy should be established and enforced to ensure that evidence of the SAM Exclusions search is retained. Staff should conduct self-review of procurement files for contracts awarded in prior years if it is known that the contract will be funded with a federal award to ensure that the SAM Exclusions search is performed prior to the expenditures of those funds and included in the procurement file. Views of responsible officials Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place.

Finding 2023-003 Procurement, Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement The regulations in 2 CFR Part 180 restrict contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participant in Federal programs or activities. Procurement policies should be established to ensure documentation is retained to verify a check was done of the Governmentwide System for Award Management Exclusions – (SAM Exclusions) prior to awarding of contracts that will be funded with federal awards. Condition Evidence was not retained in procurement documentation to support confirmation of contractor status in SAM Exclusions as an entity not subject to suspension or debarment. Cause The Association’s policies over procurement were not designed appropriately to retain evidence of SAM Exclusions search suspension and debarment review for all contracts funded with federal awards. Effect or Potential Effect Federal funds could be disbursed to suspended or debarred entities. Questioned costs Not applicable. Context Procurement testing identified a total of 1 out of 1 contracts that did not have support that the SAM Exclusions search was conducted. A contemporaneous search of SAM Exclusions did not identify these vendors as excluded. Identification as a repeat finding Not a repeat finding. Recommendation A policy should be established and enforced to ensure that evidence of the SAM Exclusions search is retained. Staff should conduct self-review of procurement files for contracts awarded in prior years if it is known that the contract will be funded with a federal award to ensure that the SAM Exclusions search is performed prior to the expenditures of those funds and included in the procurement file. Views of responsible officials Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place.

Finding 2023-004 Special Tests and Provisions - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 Health Center Program Cluster – Health Center Program/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement 42 CFR 51c.303 sets forth that community health centers are to have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay. Condition There were two patients who received discounts for sliding fee scale adjustments where there was not an approved application on file for the period in which they received services to document their ability to pay. Cause The Association's controls over retention and review of sliding fee scale applications for dental-related charges were insufficient. Effect or Potential Effect The Association is not compliant with 42 CFR 51c.303. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context There were two exceptions in the amount of $504 out of 29 items and $5,148 tested related to the Dentrix system adjustments. There were no exceptions to the 12 items and $2,164.33 tested for Cerner charges. Two additional items selected (totaling $206) from Dentrix were tested with no exception. Identification as a repeat finding Not a repeat finding. Recommendation Management should review existing processes and controls to ensure applications that document the patient’s ability to pay are retained and approved prior to applying any adjustments. Views of responsible officials Management concurs with this finding. Management plans to review adjustments to patient revenue on a quarterly basis.

Finding 2023-004 Special Tests and Provisions - Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 Health Center Program Cluster – Health Center Program/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement 42 CFR 51c.303 sets forth that community health centers are to have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay. Condition There were two patients who received discounts for sliding fee scale adjustments where there was not an approved application on file for the period in which they received services to document their ability to pay. Cause The Association's controls over retention and review of sliding fee scale applications for dental-related charges were insufficient. Effect or Potential Effect The Association is not compliant with 42 CFR 51c.303. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned costs Not applicable. Context There were two exceptions in the amount of $504 out of 29 items and $5,148 tested related to the Dentrix system adjustments. There were no exceptions to the 12 items and $2,164.33 tested for Cerner charges. Two additional items selected (totaling $206) from Dentrix were tested with no exception. Identification as a repeat finding Not a repeat finding. Recommendation Management should review existing processes and controls to ensure applications that document the patient’s ability to pay are retained and approved prior to applying any adjustments. Views of responsible officials Management concurs with this finding. Management plans to review adjustments to patient revenue on a quarterly basis.