Audit 334670

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Allowable Costs/Cost Principles – Federal: 45 CFR 75.403. State: Wisconsin Department of Health Services Allowable Cost Policy Manual (ACPM) and 2 CFR 200.403. Condition – Costs were included as a cost on more than one federal and/or state award program in the current period. Questioned Costs – Federal: $88,199. State: $4,792. Questioned costs were determined by identifying all employees who appeared on more than one grant expenditure listing and reviewing the specific payroll periods charged to each award for duplicates. Questioned costs by federal award identification number are: • Assistance Listing No. 93.224 Award No. 6 H8FCS41089 and Agreement No. 435100-G24-3919588107-390 - $2,056 • Assistance Listing No. 93.527 Award No. 6 H80CS00751 and Agreement No. 435100-G24-3919588107-90 – $2,736 • Assistance Listing No. 93.527 Award No. 6H80CS00751 and Assistance Listing No. 93.224 Award No. 6 H8FCS41089 – $83,407 Context – Salaries and wages for two employees of the Organization were identified as being charged to both Award No. 6 H80CS00751 and 6 H8FCS41089 within the Health Center Program Cluster (HCP) for five to seven months during the fiscal year. For two other employees, salaries and wages were identified as being charged to both the Wisconsin Department of Health Community Health Center Program (CHCG) and one of the awards in the HCP, but instances were limited to only certain payroll periods. Effect – The Organization charged payroll expenditures to more than one funding stream within the HCP and CHCG grant awards. Cause – Salaries and wages are charged to federal and state awards through separate manual tracking spreadsheets, which link back to payroll supporting documentation summarized monthly based on pay date. The Organization’s internal controls intended to prevent charging amounts to more than one award includes a separate spreadsheet listing all employees and identifying the budgeted percentage of salaries and wages associated with each federal and state awards. The system was not accurately updated to reflect changes throughout the year or monitored when the Organization prepared “catch-up” drawdowns after-the-fact to justify use of remaining available grant funds. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consolidate tracking of salaries and wages charged to federal and state awards into a single listing for each payroll period rather than separate spreadsheets based on summarized monthly payroll data. The Organization should support the distribution of employees’ salaries and wages amongst federal and state awards to accurately reflect the work performed through the timekeeping system and payroll records. Views of responsible officials and planned corrective actions – Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Allowable Costs/Cost Principles – Federal: 45 CFR 75.403. State: Wisconsin Department of Health Services Allowable Cost Policy Manual (ACPM) and 2 CFR 200.403. Condition – Costs were included as a cost on more than one federal and/or state award program in the current period. Questioned Costs – Federal: $88,199. State: $4,792. Questioned costs were determined by identifying all employees who appeared on more than one grant expenditure listing and reviewing the specific payroll periods charged to each award for duplicates. Questioned costs by federal award identification number are: • Assistance Listing No. 93.224 Award No. 6 H8FCS41089 and Agreement No. 435100-G24-3919588107-390 - $2,056 • Assistance Listing No. 93.527 Award No. 6 H80CS00751 and Agreement No. 435100-G24-3919588107-90 – $2,736 • Assistance Listing No. 93.527 Award No. 6H80CS00751 and Assistance Listing No. 93.224 Award No. 6 H8FCS41089 – $83,407 Context – Salaries and wages for two employees of the Organization were identified as being charged to both Award No. 6 H80CS00751 and 6 H8FCS41089 within the Health Center Program Cluster (HCP) for five to seven months during the fiscal year. For two other employees, salaries and wages were identified as being charged to both the Wisconsin Department of Health Community Health Center Program (CHCG) and one of the awards in the HCP, but instances were limited to only certain payroll periods. Effect – The Organization charged payroll expenditures to more than one funding stream within the HCP and CHCG grant awards. Cause – Salaries and wages are charged to federal and state awards through separate manual tracking spreadsheets, which link back to payroll supporting documentation summarized monthly based on pay date. The Organization’s internal controls intended to prevent charging amounts to more than one award includes a separate spreadsheet listing all employees and identifying the budgeted percentage of salaries and wages associated with each federal and state awards. The system was not accurately updated to reflect changes throughout the year or monitored when the Organization prepared “catch-up” drawdowns after-the-fact to justify use of remaining available grant funds. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consolidate tracking of salaries and wages charged to federal and state awards into a single listing for each payroll period rather than separate spreadsheets based on summarized monthly payroll data. The Organization should support the distribution of employees’ salaries and wages amongst federal and state awards to accurately reflect the work performed through the timekeeping system and payroll records. Views of responsible officials and planned corrective actions – Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Period of Performance – Federal: 45 CFR 75.309. State: 2 CFR 200.430. Condition – Costs charged to the grant award were incurred prior to the start of the period of performance. Questioned Costs – Federal: $103,466. State: $5,195. Questioned costs were determined by identifying salaries and wages incurred prior to the beginning of the period of performance based on payroll periods and pay dates. Questioned costs by federal or state award identification number are: • Assistance Listing No. 93.527 Award No. 6 H80CS00751 – $103,466 • Agreement No. 435100-G24-3919588107-90 – $5,195 Context – Salaries and wages from the first pay period paid during the period of performance was charged to the federal and state awards. For Award No. 6 H80CS00751 within Health Center Program Cluster (HCP), payroll paid on April 7, 2023, was charged to the federal award, while 100% of payroll costs were incurred as of March 31, 2023. For Agreement No. 435100-G24-3919588107-90 within Wisconsin Department of Health Community Health Center Program (CHCG), payroll paid on June 14, 2023, was charged to the state award, while 50% of payroll costs were incurred as of June 30, 2023. Effect – The Organization charged salaries and wages incurred prior to the beginning of the period of performance in both HCP and CHCG. Cause – Salaries and wages are charged to federal and state awards based on payroll documentation summarized monthly based on pay date rather than accrual-based salary and wage expense. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should implement cut-off procedures to ensure grant expenditures are captured on the accrual-basis consistent with period of performance compliance requirements and generally accepted accounting principles. To more easily accomplish this, the Organization should identify allowable salaries and wages by payroll period rather than from payroll data summarized monthly by pay date. Views of responsible officials and planned corrective actions – Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of noncompliance (such as cash management). Although the initial support provided to auditors contained instances of expenditures incurred prior to the beginning of the period of performance, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes for cut-off procedures related to grant expenditures. We will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff by lining up grant expenditures with pay periods instead of monthly allocations. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Criteria or Specific Requirement – Reporting and Period of Performance – 45 CFR 75.342 and 45 CFR 75.309. Condition – A financial report submitted during the year was not prepared accurately based on financial information. As a result, grant funds were carried over into the subsequent grant budget period even though allowable costs had been incurred. Questioned Costs – $381,630. Questioned costs were determined based on the amount of grant expenditures reported as unobligated but incurred by March 31, 2023. Context – The Organization is required to report federal funding awarded and expended, along with program income earned and expended, on annual Federal Financial Reports (FFRs) for each federal award. A sample of one FFR was tested out of a population of four financial reports submitted by the Organization during the year. Samples were not, and were not intended to be, statistically valid. Federal funding expended was understated by $381,630, the amount of grant expenditures incurred, but not disbursed at year-end, on the annual FFR for Award No. 6 H80CS00751, resulting in an overstatement of the unobligated balance at March 31, 2023, and carryover of grant funds into the grant period ending March 31, 2024. Additionally, the Organization failed to report program income earned and expended cumulatively. Effect – The Organization improperly reported $381,630 of grant funds as unobligated at March 31, 2023, resulting in the carryover of grant funds into the grant period ending March 31, 2024, although funds had already been obligated as of March 31, 2023. The Organization’s cumulative tracking of unearned program income and, therefore, its reserve, is not accurate. Cause – The annual FFR was not prepared based on accurate accrual-basis and cumulative financial information. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider revising the annual FFR due to inappropriate carryover of obligated grant funds. Going forward, the Organization should ensure financial reporting is prepared based on accurate accrual-basis financial information and, where appropriate, presented cumulatively. Views of responsible officials and planned corrective actions – The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also reviewed our internal process for FFR submission. In general, we do not have carryover on our FFR, and this error occurred due to the additional Covid-19 funding the organization had received. Relevant staff participated in a training focused on CHC grants management matters, including preparation of the FFR, in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Criteria or Specific Requirement – Reporting and Period of Performance – 45 CFR 75.342 and 45 CFR 75.309. Condition – A financial report submitted during the year was not prepared accurately based on financial information. As a result, grant funds were carried over into the subsequent grant budget period even though allowable costs had been incurred. Questioned Costs – $381,630. Questioned costs were determined based on the amount of grant expenditures reported as unobligated but incurred by March 31, 2023. Context – The Organization is required to report federal funding awarded and expended, along with program income earned and expended, on annual Federal Financial Reports (FFRs) for each federal award. A sample of one FFR was tested out of a population of four financial reports submitted by the Organization during the year. Samples were not, and were not intended to be, statistically valid. Federal funding expended was understated by $381,630, the amount of grant expenditures incurred, but not disbursed at year-end, on the annual FFR for Award No. 6 H80CS00751, resulting in an overstatement of the unobligated balance at March 31, 2023, and carryover of grant funds into the grant period ending March 31, 2024. Additionally, the Organization failed to report program income earned and expended cumulatively. Effect – The Organization improperly reported $381,630 of grant funds as unobligated at March 31, 2023, resulting in the carryover of grant funds into the grant period ending March 31, 2024, although funds had already been obligated as of March 31, 2023. The Organization’s cumulative tracking of unearned program income and, therefore, its reserve, is not accurate. Cause – The annual FFR was not prepared based on accurate accrual-basis and cumulative financial information. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider revising the annual FFR due to inappropriate carryover of obligated grant funds. Going forward, the Organization should ensure financial reporting is prepared based on accurate accrual-basis financial information and, where appropriate, presented cumulatively. Views of responsible officials and planned corrective actions – The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also reviewed our internal process for FFR submission. In general, we do not have carryover on our FFR, and this error occurred due to the additional Covid-19 funding the organization had received. Relevant staff participated in a training focused on CHC grants management matters, including preparation of the FFR, in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Allowable Costs/Cost Principles – Federal: 45 CFR 75.403. State: Wisconsin Department of Health Services Allowable Cost Policy Manual (ACPM) and 2 CFR 200.403. Condition – Costs were included as a cost on more than one federal and/or state award program in the current period. Questioned Costs – Federal: $88,199. State: $4,792. Questioned costs were determined by identifying all employees who appeared on more than one grant expenditure listing and reviewing the specific payroll periods charged to each award for duplicates. Questioned costs by federal award identification number are: • Assistance Listing No. 93.224 Award No. 6 H8FCS41089 and Agreement No. 435100-G24-3919588107-390 - $2,056 • Assistance Listing No. 93.527 Award No. 6 H80CS00751 and Agreement No. 435100-G24-3919588107-90 – $2,736 • Assistance Listing No. 93.527 Award No. 6H80CS00751 and Assistance Listing No. 93.224 Award No. 6 H8FCS41089 – $83,407 Context – Salaries and wages for two employees of the Organization were identified as being charged to both Award No. 6 H80CS00751 and 6 H8FCS41089 within the Health Center Program Cluster (HCP) for five to seven months during the fiscal year. For two other employees, salaries and wages were identified as being charged to both the Wisconsin Department of Health Community Health Center Program (CHCG) and one of the awards in the HCP, but instances were limited to only certain payroll periods. Effect – The Organization charged payroll expenditures to more than one funding stream within the HCP and CHCG grant awards. Cause – Salaries and wages are charged to federal and state awards through separate manual tracking spreadsheets, which link back to payroll supporting documentation summarized monthly based on pay date. The Organization’s internal controls intended to prevent charging amounts to more than one award includes a separate spreadsheet listing all employees and identifying the budgeted percentage of salaries and wages associated with each federal and state awards. The system was not accurately updated to reflect changes throughout the year or monitored when the Organization prepared “catch-up” drawdowns after-the-fact to justify use of remaining available grant funds. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consolidate tracking of salaries and wages charged to federal and state awards into a single listing for each payroll period rather than separate spreadsheets based on summarized monthly payroll data. The Organization should support the distribution of employees’ salaries and wages amongst federal and state awards to accurately reflect the work performed through the timekeeping system and payroll records. Views of responsible officials and planned corrective actions – Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Allowable Costs/Cost Principles – Federal: 45 CFR 75.403. State: Wisconsin Department of Health Services Allowable Cost Policy Manual (ACPM) and 2 CFR 200.403. Condition – Costs were included as a cost on more than one federal and/or state award program in the current period. Questioned Costs – Federal: $88,199. State: $4,792. Questioned costs were determined by identifying all employees who appeared on more than one grant expenditure listing and reviewing the specific payroll periods charged to each award for duplicates. Questioned costs by federal award identification number are: • Assistance Listing No. 93.224 Award No. 6 H8FCS41089 and Agreement No. 435100-G24-3919588107-390 - $2,056 • Assistance Listing No. 93.527 Award No. 6 H80CS00751 and Agreement No. 435100-G24-3919588107-90 – $2,736 • Assistance Listing No. 93.527 Award No. 6H80CS00751 and Assistance Listing No. 93.224 Award No. 6 H8FCS41089 – $83,407 Context – Salaries and wages for two employees of the Organization were identified as being charged to both Award No. 6 H80CS00751 and 6 H8FCS41089 within the Health Center Program Cluster (HCP) for five to seven months during the fiscal year. For two other employees, salaries and wages were identified as being charged to both the Wisconsin Department of Health Community Health Center Program (CHCG) and one of the awards in the HCP, but instances were limited to only certain payroll periods. Effect – The Organization charged payroll expenditures to more than one funding stream within the HCP and CHCG grant awards. Cause – Salaries and wages are charged to federal and state awards through separate manual tracking spreadsheets, which link back to payroll supporting documentation summarized monthly based on pay date. The Organization’s internal controls intended to prevent charging amounts to more than one award includes a separate spreadsheet listing all employees and identifying the budgeted percentage of salaries and wages associated with each federal and state awards. The system was not accurately updated to reflect changes throughout the year or monitored when the Organization prepared “catch-up” drawdowns after-the-fact to justify use of remaining available grant funds. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consolidate tracking of salaries and wages charged to federal and state awards into a single listing for each payroll period rather than separate spreadsheets based on summarized monthly payroll data. The Organization should support the distribution of employees’ salaries and wages amongst federal and state awards to accurately reflect the work performed through the timekeeping system and payroll records. Views of responsible officials and planned corrective actions – Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Period of Performance – Federal: 45 CFR 75.309. State: 2 CFR 200.430. Condition – Costs charged to the grant award were incurred prior to the start of the period of performance. Questioned Costs – Federal: $103,466. State: $5,195. Questioned costs were determined by identifying salaries and wages incurred prior to the beginning of the period of performance based on payroll periods and pay dates. Questioned costs by federal or state award identification number are: • Assistance Listing No. 93.527 Award No. 6 H80CS00751 – $103,466 • Agreement No. 435100-G24-3919588107-90 – $5,195 Context – Salaries and wages from the first pay period paid during the period of performance was charged to the federal and state awards. For Award No. 6 H80CS00751 within Health Center Program Cluster (HCP), payroll paid on April 7, 2023, was charged to the federal award, while 100% of payroll costs were incurred as of March 31, 2023. For Agreement No. 435100-G24-3919588107-90 within Wisconsin Department of Health Community Health Center Program (CHCG), payroll paid on June 14, 2023, was charged to the state award, while 50% of payroll costs were incurred as of June 30, 2023. Effect – The Organization charged salaries and wages incurred prior to the beginning of the period of performance in both HCP and CHCG. Cause – Salaries and wages are charged to federal and state awards based on payroll documentation summarized monthly based on pay date rather than accrual-based salary and wage expense. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should implement cut-off procedures to ensure grant expenditures are captured on the accrual-basis consistent with period of performance compliance requirements and generally accepted accounting principles. To more easily accomplish this, the Organization should identify allowable salaries and wages by payroll period rather than from payroll data summarized monthly by pay date. Views of responsible officials and planned corrective actions – Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of noncompliance (such as cash management). Although the initial support provided to auditors contained instances of expenditures incurred prior to the beginning of the period of performance, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes for cut-off procedures related to grant expenditures. We will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff by lining up grant expenditures with pay periods instead of monthly allocations. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Criteria or Specific Requirement – Reporting and Period of Performance – 45 CFR 75.342 and 45 CFR 75.309. Condition – A financial report submitted during the year was not prepared accurately based on financial information. As a result, grant funds were carried over into the subsequent grant budget period even though allowable costs had been incurred. Questioned Costs – $381,630. Questioned costs were determined based on the amount of grant expenditures reported as unobligated but incurred by March 31, 2023. Context – The Organization is required to report federal funding awarded and expended, along with program income earned and expended, on annual Federal Financial Reports (FFRs) for each federal award. A sample of one FFR was tested out of a population of four financial reports submitted by the Organization during the year. Samples were not, and were not intended to be, statistically valid. Federal funding expended was understated by $381,630, the amount of grant expenditures incurred, but not disbursed at year-end, on the annual FFR for Award No. 6 H80CS00751, resulting in an overstatement of the unobligated balance at March 31, 2023, and carryover of grant funds into the grant period ending March 31, 2024. Additionally, the Organization failed to report program income earned and expended cumulatively. Effect – The Organization improperly reported $381,630 of grant funds as unobligated at March 31, 2023, resulting in the carryover of grant funds into the grant period ending March 31, 2024, although funds had already been obligated as of March 31, 2023. The Organization’s cumulative tracking of unearned program income and, therefore, its reserve, is not accurate. Cause – The annual FFR was not prepared based on accurate accrual-basis and cumulative financial information. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider revising the annual FFR due to inappropriate carryover of obligated grant funds. Going forward, the Organization should ensure financial reporting is prepared based on accurate accrual-basis financial information and, where appropriate, presented cumulatively. Views of responsible officials and planned corrective actions – The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also reviewed our internal process for FFR submission. In general, we do not have carryover on our FFR, and this error occurred due to the additional Covid-19 funding the organization had received. Relevant staff participated in a training focused on CHC grants management matters, including preparation of the FFR, in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Criteria or Specific Requirement – Reporting and Period of Performance – 45 CFR 75.342 and 45 CFR 75.309. Condition – A financial report submitted during the year was not prepared accurately based on financial information. As a result, grant funds were carried over into the subsequent grant budget period even though allowable costs had been incurred. Questioned Costs – $381,630. Questioned costs were determined based on the amount of grant expenditures reported as unobligated but incurred by March 31, 2023. Context – The Organization is required to report federal funding awarded and expended, along with program income earned and expended, on annual Federal Financial Reports (FFRs) for each federal award. A sample of one FFR was tested out of a population of four financial reports submitted by the Organization during the year. Samples were not, and were not intended to be, statistically valid. Federal funding expended was understated by $381,630, the amount of grant expenditures incurred, but not disbursed at year-end, on the annual FFR for Award No. 6 H80CS00751, resulting in an overstatement of the unobligated balance at March 31, 2023, and carryover of grant funds into the grant period ending March 31, 2024. Additionally, the Organization failed to report program income earned and expended cumulatively. Effect – The Organization improperly reported $381,630 of grant funds as unobligated at March 31, 2023, resulting in the carryover of grant funds into the grant period ending March 31, 2024, although funds had already been obligated as of March 31, 2023. The Organization’s cumulative tracking of unearned program income and, therefore, its reserve, is not accurate. Cause – The annual FFR was not prepared based on accurate accrual-basis and cumulative financial information. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider revising the annual FFR due to inappropriate carryover of obligated grant funds. Going forward, the Organization should ensure financial reporting is prepared based on accurate accrual-basis financial information and, where appropriate, presented cumulatively. Views of responsible officials and planned corrective actions – The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also reviewed our internal process for FFR submission. In general, we do not have carryover on our FFR, and this error occurred due to the additional Covid-19 funding the organization had received. Relevant staff participated in a training focused on CHC grants management matters, including preparation of the FFR, in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts – 42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303(f) Condition – Sliding fee discounts applied to patient charges were inconsistent with the Organization’s sliding fee discount schedule. Questioned Costs – None Context – A sample of 25 encounters out of a population of approximately 54,288 encounters were tested and 4 instances of inappropriate sliding fee adjustments were identified. The sampling methodology used is not and is not intended to be statistically valid. Effect – The patients’ responsibility for services rendered by the Organization was inconsistent with the stated sliding fee discount schedules. Cause – The Organization’s sliding fee discount schedules are very nuanced and difficult to automate in the practice management system. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should review the sliding fee discount policy and schedules to ensure compliance with the Health Center Program Compliance Manual while considering improvements that can be made for both patient and personnel understanding and increased accuracy of system-generated adjustments. The Organization should also continue educating personnel on the sliding fee discount program and consider implementing internal audits of sliding fee adjustments to monitor and identify specific areas for further improvements or training. Views of responsible officials and planned corrective actions – The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.