Audit 341568

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-002 – Allowable Costs/Cost Principles Identification of the federal program: U.S. Department of Health and Human Services Medicaid Cluster Assistance Listing No. 93.778 Medical Assistance Program Passed through County of Los Angeles Department of Public Health Pass Through Number Pass Through Entity Grant Period PH-004983 County of Los Angeles 10/1/2022–06/30/2025 Dignity Community Care, DBA California Hospital Medical Center Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: At California Hospital Medical Center, internal controls over the required allowability criteria with regard to payroll expense were not performed for 3 of 60 employees selected for testing. Cause: California Hospital Medical Center management did not consistently perform the necessary internal control procedures addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: None. Context: For 3 of 60 payroll expenditures selected for testing, California Hospital Medical Center management did not properly approve the employee timecard for time charged to the grant in accordance with the practices of California Hospital Medical Center. Total payroll expenditures for California Hospital Medical Center were approximately $0.2 million and represent 7% of the total Medical Assistance Program expenditures of approximately $3.3 million. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend management execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. Views of responsible officials: Management agrees with the finding and implemented corrective action in July 2024, to require approval of timecards.

Finding 2024-003 – Special Tests and Provisions – Return of Title IV Funds Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.” Condition: Good Samaritan College of Nursing & Health Science did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to the U.S. Department of Education. Good Samaritan College of Nursing & Health Science did not calculate and return Title IV funds in a timely manner to the U.S. Department of Education for 1 of 5 students within 45 days after the date the institution determined that the student withdrew. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. Effect or potential effect: Good Samaritan College of Nursing & Health Science is not returning Title IV funds within the required time frame to the U.S. Department of Education, resulting in noncompliance. Questioned costs: None. Context: After obtaining an understanding of the internal controls over return of Title IV funds, we determined internal controls were not designed sufficiently to ensure compliance with timely calculation and returns of Title IV funds. EY selected and tested 5 students from the population of 18 students who withdrew during the year ended June 30, 2024. Of the 5 students selected, returns of Title IV funds were required for all 5 of the students. For 1 of the 5 students who required a return, Good Samaritan College of Nursing & Health Science calculated and returned the funds after 45 days from the date Good Samaritan College of Nursing & Health Science determined the student withdrew. The return of Title IV funds for that student was made in 58 days and totaled $3,761 and consisted of Direct Loans. Total direct loans for Good Samaritan College of Nursing & Health Science are approximately $4.0 million, representing 70% of Good Samaritan College of Nursing & Health Science’s SFA Cluster expenditures of approximately $5.7 million, and 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Finding 2023-012. Recommendation: Management should review and revise its internal controls and procedures in place over the return of Title IV funds to ensure that the returns of Title IV funds are made within the required time frame. Views of responsible officials: Management agrees with the finding and implemented corrective action in April 2024.

Finding 2024-004 – Eligibility Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Number Pass Through Entity Grant Period 10126 PREV King County Public Health 3/1/2023–2/29/2024 11987 PREV King County Public Health 3/1/2024–2/28/2025 Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Bailey-Boushay House has processes in place to verify whether participants are eligible; however, documentation to evidence the execution of the controls was not retained. Cause: Bailey-Boushay House management did not retain evidence of the execution of controls due to lack of understanding of the need to retain the documentation. Effect or potential effect: Ineligible individuals may be provided services. Questioned costs: None. Context: Total expenditures for Bailey-Boushay House were approximately $1.4 million and represent 29.8% of the total HIV program expenditures of approximately $4.6 million. However, expenditures are not based upon serving eligible patients. Due to the lack of retaining evidence to document controls, EY did not select controls to test. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend management maintain evidence of the execution of internal controls related to documentation that individuals served are eligible to participate in the program. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan to include retaining evidence to support the execution of controls over eligibility determinations. The corrective action will be implemented in February 2025.

Finding 2024-005 - Special Tests and Provisions - Enrollment Reporting Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Pell Grant Program Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Institutions are responsible for accurately reporting to the National Student Loan Data System (NSLDS) the following significant data elements under the Campus-Level Record and Program-Level Record that Department of Education (ED) considers high risk. ED considers the following Campus-Level data elements to be high risk: 1. Office of Postsecondary Education Identification (OPEID) Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date ED considers the following Program-Level Record data elements to be high risk: 1. OPEID Number 2. CIP Code 3. CIP Year 4. Credential Level 5. Published Program Length Measurement 6. Published Program Length 7. Program Begin Date 8. Program Enrollment Status 9. Program Enrollment Effective Date When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. Condition: Good Samaritan College of Nursing & Health Science did not have effective internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding over enrollment reporting; however, ineffective internal control led to untimely reporting and inaccurate data reported for certain students. Additionally, in the current year, a different matter was noted in that the third-party system that is used to generate reports to validate status changes was not accurate, resulting in certain enrollment status changes not being submitted to NSLDS timely. Effect or potential effect: Lack of internal controls over timely and accurate enrollment reporting resulted in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is important for effective management of the programs. Questioned costs: None. Context: EY selected 61 students from a population of 121 students receiving Pell and Direct Student Loans to test whether the required student enrollment information was accurately and timely reported to NSLDS. For the 61 students selected for testing, we tested 16 attributes for each student, for a total of 976 attributes. Of the 61 students selected, enrollment status was not reported timely, within 60 days, for 4 students receiving direct loans, with reporting to NSLDS ranging from 73 to 187 days. Additionally, of the 61 students selected, for 2 students receiving a direct loan, the correct enrollment status of withdrawn was never reported to NSLDS. As a result of the enrollment status for 6 students being reported late or inaccurately, we noted Campus-Level information was inaccurate in 10 instances for 3 data elements and Program-Level information was inaccurate in 4 instances for 2 data elements. In addition, of the 61 students selected, the program begin date was inaccurately reported for 2 students. Good Samaritan College of Nursing & Health Science has SFA Cluster expenditures of approximately $5.7 million, which makes up 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Findings 2023-010, 2022-005, and 2021-006. An additional internal control matter related to enrollment status is reported in the current year and is a different matter from that reported in the prior years. Recommendation: Good Samaritan College of Nursing & Health Science should refine processes and develop internal controls over enrollment reporting requirements to ensure information used to determine status changes is complete and accurate and that changes in enrollment status are reported timely. Views of responsible officials: Management at Good Samaritan College of Nursing & Health Science agrees with the finding and will work with the student financial aid vendor to ensure all status changes are appropriately captured.

Finding 2024-005 - Special Tests and Provisions - Enrollment Reporting Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Pell Grant Program Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Institutions are responsible for accurately reporting to the National Student Loan Data System (NSLDS) the following significant data elements under the Campus-Level Record and Program-Level Record that Department of Education (ED) considers high risk. ED considers the following Campus-Level data elements to be high risk: 1. Office of Postsecondary Education Identification (OPEID) Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date ED considers the following Program-Level Record data elements to be high risk: 1. OPEID Number 2. CIP Code 3. CIP Year 4. Credential Level 5. Published Program Length Measurement 6. Published Program Length 7. Program Begin Date 8. Program Enrollment Status 9. Program Enrollment Effective Date When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. Condition: Good Samaritan College of Nursing & Health Science did not have effective internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding over enrollment reporting; however, ineffective internal control led to untimely reporting and inaccurate data reported for certain students. Additionally, in the current year, a different matter was noted in that the third-party system that is used to generate reports to validate status changes was not accurate, resulting in certain enrollment status changes not being submitted to NSLDS timely. Effect or potential effect: Lack of internal controls over timely and accurate enrollment reporting resulted in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is important for effective management of the programs. Questioned costs: None. Context: EY selected 61 students from a population of 121 students receiving Pell and Direct Student Loans to test whether the required student enrollment information was accurately and timely reported to NSLDS. For the 61 students selected for testing, we tested 16 attributes for each student, for a total of 976 attributes. Of the 61 students selected, enrollment status was not reported timely, within 60 days, for 4 students receiving direct loans, with reporting to NSLDS ranging from 73 to 187 days. Additionally, of the 61 students selected, for 2 students receiving a direct loan, the correct enrollment status of withdrawn was never reported to NSLDS. As a result of the enrollment status for 6 students being reported late or inaccurately, we noted Campus-Level information was inaccurate in 10 instances for 3 data elements and Program-Level information was inaccurate in 4 instances for 2 data elements. In addition, of the 61 students selected, the program begin date was inaccurately reported for 2 students. Good Samaritan College of Nursing & Health Science has SFA Cluster expenditures of approximately $5.7 million, which makes up 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Findings 2023-010, 2022-005, and 2021-006. An additional internal control matter related to enrollment status is reported in the current year and is a different matter from that reported in the prior years. Recommendation: Good Samaritan College of Nursing & Health Science should refine processes and develop internal controls over enrollment reporting requirements to ensure information used to determine status changes is complete and accurate and that changes in enrollment status are reported timely. Views of responsible officials: Management at Good Samaritan College of Nursing & Health Science agrees with the finding and will work with the student financial aid vendor to ensure all status changes are appropriately captured.

Finding 2024-006 – Allowable Costs/Cost Principles Identification of the federal program: U.S. Department of Treasury Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-through entity: County of Los Angeles Pass-through number: PH-005009 St. Mary Medical Center – Long Beach Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: St. Mary Medical Center – Long Beach did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. Cause: St. Mary Medical Center – Long Beach did not have controls in place to ensure that all timecards were approved. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: No questioned costs. Context: We selected 25 payroll transactions totaling $8,621. Of the 25 transactions selected for testing, 2 timecards with supporting payroll expenditures of $246 were not appropriately approved. We did not note any noncompliance with 2 CFR 200.430. Total payroll expenditures for St. Mary Medical Center – Long Beach were $80,190 and represent approximately 6% of the total program expenditures of approximately $1.4 million. Identification of a repeat finding: This is a not a repeat finding as this program was not previously subject to audit. Recommendation: We recommend management at St. Mary Medical Center – Long Beach execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period PH-002898 County of Los Angeles 01/11/2011–02/28/2025 PH-002375 County of Los Angeles 12/01/2012–06/30/2025 PH-003746 County of Los Angeles 12/01/2012–06/30/2025 PH-003802 County of Los Angeles 01/01/2013–06/30/2025 H-208518 County of Los Angeles 04/01/2006–07/31/2025 PH-004205 County of Los Angeles 06/01/2020–02/28/2025 10126 PREV King County Public Health 03/01/2023–02/29/2024 11987 PREV King County Public Health 03/01/2024–02/28/2025 St. Mary Medical Center – Long Beach Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Bailey-Boushay House Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Only expenditures incurred related to the federal program should be requested for reimbursement. Condition: St. Mary Medical Center – Long Beach and Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. At Bailey-Boushay House, one employee’s salary that was charged to the grant was not supported by the underlying timesheet for the respective pay period and the related expenditures should not have been charged to the grant and requested for reimbursement. Cause: St. Mary Medical Center – Long Beach and Bailey-Boushay House management have been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. For one employee at Bailey-Boushay House, the timecard reflected zero hours for grant award 10126-PREV. There was a clerical error whereby the hours transferred from the timecard were reported to the wrong grant, resulting in an overcharge to the federal grant. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: $504, calculated as the amount charged to the grant that was not supported by the underlying time sheet for one employee. Context: We issued a material weakness for St. Mary Medical Center – Long Beach and Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. For one employee, the clerical error resulted in an overcharge to the grant. Total payroll expenditures for St. Mary Medical Center – Long Beach were approximately $1.1 million and represent 24% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.4 million and represent 30% of the total HIV Emergency Relief Project Grants expenditures of approximately $4.6 million. We selected a sample of 43 payroll expenditures totaling $52,706 to perform compliance testing. Of the 43 samples, 18 samples totaling $18,451 and 25 samples totaling $34,255 were obtained from Bailey-Boushay House and St. Mary Medical Center – Long Beach, respectively. For 1 of the 18 samples selected from Bailey-Boushay House, comprising $403 in salary and $101 in related fringe benefit expense, for a total of $504, the expenditures were not supported by the related employee timesheet. Identification of a repeat finding: This is a repeat finding for St. Mary Medical Center – Long Beach – Finding 2023-003. For internal controls, this is a repeat finding for Bailey-Boushay House – Findings 2023-003, 2022-007, and 2021-008, but this current year finding is the first time noncompliance has been noted in our testing. Recommendation: We recommend management at St. Mary Medical Center – Long Beach and Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. At Bailey-Boushay House, we recommend that only expenses supported by an underlying timesheet be charged to the grant. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024. For the noncompliance noted at Bailey-Boushay House, Bailey-Boushay House will return the funds to the grantor for amounts that were not supported by an underlying timesheet.

Finding 2024-002 – Allowable Costs/Cost Principles Identification of the federal program: U.S. Department of Health and Human Services Medicaid Cluster Assistance Listing No. 93.778 Medical Assistance Program Passed through County of Los Angeles Department of Public Health Pass Through Number Pass Through Entity Grant Period PH-004983 County of Los Angeles 10/1/2022–06/30/2025 Dignity Community Care, DBA California Hospital Medical Center Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: At California Hospital Medical Center, internal controls over the required allowability criteria with regard to payroll expense were not performed for 3 of 60 employees selected for testing. Cause: California Hospital Medical Center management did not consistently perform the necessary internal control procedures addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: None. Context: For 3 of 60 payroll expenditures selected for testing, California Hospital Medical Center management did not properly approve the employee timecard for time charged to the grant in accordance with the practices of California Hospital Medical Center. Total payroll expenditures for California Hospital Medical Center were approximately $0.2 million and represent 7% of the total Medical Assistance Program expenditures of approximately $3.3 million. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend management execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. Views of responsible officials: Management agrees with the finding and implemented corrective action in July 2024, to require approval of timecards.

Finding 2024-003 – Special Tests and Provisions – Return of Title IV Funds Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.” Condition: Good Samaritan College of Nursing & Health Science did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to the U.S. Department of Education. Good Samaritan College of Nursing & Health Science did not calculate and return Title IV funds in a timely manner to the U.S. Department of Education for 1 of 5 students within 45 days after the date the institution determined that the student withdrew. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding; however, controls were not implemented during the entire period under audit. Effect or potential effect: Good Samaritan College of Nursing & Health Science is not returning Title IV funds within the required time frame to the U.S. Department of Education, resulting in noncompliance. Questioned costs: None. Context: After obtaining an understanding of the internal controls over return of Title IV funds, we determined internal controls were not designed sufficiently to ensure compliance with timely calculation and returns of Title IV funds. EY selected and tested 5 students from the population of 18 students who withdrew during the year ended June 30, 2024. Of the 5 students selected, returns of Title IV funds were required for all 5 of the students. For 1 of the 5 students who required a return, Good Samaritan College of Nursing & Health Science calculated and returned the funds after 45 days from the date Good Samaritan College of Nursing & Health Science determined the student withdrew. The return of Title IV funds for that student was made in 58 days and totaled $3,761 and consisted of Direct Loans. Total direct loans for Good Samaritan College of Nursing & Health Science are approximately $4.0 million, representing 70% of Good Samaritan College of Nursing & Health Science’s SFA Cluster expenditures of approximately $5.7 million, and 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Finding 2023-012. Recommendation: Management should review and revise its internal controls and procedures in place over the return of Title IV funds to ensure that the returns of Title IV funds are made within the required time frame. Views of responsible officials: Management agrees with the finding and implemented corrective action in April 2024.

Finding 2024-004 – Eligibility Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Number Pass Through Entity Grant Period 10126 PREV King County Public Health 3/1/2023–2/29/2024 11987 PREV King County Public Health 3/1/2024–2/28/2025 Bailey-Boushay House Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Bailey-Boushay House has processes in place to verify whether participants are eligible; however, documentation to evidence the execution of the controls was not retained. Cause: Bailey-Boushay House management did not retain evidence of the execution of controls due to lack of understanding of the need to retain the documentation. Effect or potential effect: Ineligible individuals may be provided services. Questioned costs: None. Context: Total expenditures for Bailey-Boushay House were approximately $1.4 million and represent 29.8% of the total HIV program expenditures of approximately $4.6 million. However, expenditures are not based upon serving eligible patients. Due to the lack of retaining evidence to document controls, EY did not select controls to test. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend management maintain evidence of the execution of internal controls related to documentation that individuals served are eligible to participate in the program. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan to include retaining evidence to support the execution of controls over eligibility determinations. The corrective action will be implemented in February 2025.

Finding 2024-005 - Special Tests and Provisions - Enrollment Reporting Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Pell Grant Program Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Institutions are responsible for accurately reporting to the National Student Loan Data System (NSLDS) the following significant data elements under the Campus-Level Record and Program-Level Record that Department of Education (ED) considers high risk. ED considers the following Campus-Level data elements to be high risk: 1. Office of Postsecondary Education Identification (OPEID) Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date ED considers the following Program-Level Record data elements to be high risk: 1. OPEID Number 2. CIP Code 3. CIP Year 4. Credential Level 5. Published Program Length Measurement 6. Published Program Length 7. Program Begin Date 8. Program Enrollment Status 9. Program Enrollment Effective Date When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. Condition: Good Samaritan College of Nursing & Health Science did not have effective internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding over enrollment reporting; however, ineffective internal control led to untimely reporting and inaccurate data reported for certain students. Additionally, in the current year, a different matter was noted in that the third-party system that is used to generate reports to validate status changes was not accurate, resulting in certain enrollment status changes not being submitted to NSLDS timely. Effect or potential effect: Lack of internal controls over timely and accurate enrollment reporting resulted in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is important for effective management of the programs. Questioned costs: None. Context: EY selected 61 students from a population of 121 students receiving Pell and Direct Student Loans to test whether the required student enrollment information was accurately and timely reported to NSLDS. For the 61 students selected for testing, we tested 16 attributes for each student, for a total of 976 attributes. Of the 61 students selected, enrollment status was not reported timely, within 60 days, for 4 students receiving direct loans, with reporting to NSLDS ranging from 73 to 187 days. Additionally, of the 61 students selected, for 2 students receiving a direct loan, the correct enrollment status of withdrawn was never reported to NSLDS. As a result of the enrollment status for 6 students being reported late or inaccurately, we noted Campus-Level information was inaccurate in 10 instances for 3 data elements and Program-Level information was inaccurate in 4 instances for 2 data elements. In addition, of the 61 students selected, the program begin date was inaccurately reported for 2 students. Good Samaritan College of Nursing & Health Science has SFA Cluster expenditures of approximately $5.7 million, which makes up 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Findings 2023-010, 2022-005, and 2021-006. An additional internal control matter related to enrollment status is reported in the current year and is a different matter from that reported in the prior years. Recommendation: Good Samaritan College of Nursing & Health Science should refine processes and develop internal controls over enrollment reporting requirements to ensure information used to determine status changes is complete and accurate and that changes in enrollment status are reported timely. Views of responsible officials: Management at Good Samaritan College of Nursing & Health Science agrees with the finding and will work with the student financial aid vendor to ensure all status changes are appropriately captured.

Finding 2024-005 - Special Tests and Provisions - Enrollment Reporting Identification of the federal program: U.S. Department of Education Office of Federal Student Aid Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Pell Grant Program Assistance Listing No. 84.268 Federal Direct Student Loans Good Samaritan College of Nursing & Health Science Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be compliance with guidance in “Standards for Internal Control the Federal Government” issued by the Comptroller General the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Institutions are responsible for accurately reporting to the National Student Loan Data System (NSLDS) the following significant data elements under the Campus-Level Record and Program-Level Record that Department of Education (ED) considers high risk. ED considers the following Campus-Level data elements to be high risk: 1. Office of Postsecondary Education Identification (OPEID) Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date ED considers the following Program-Level Record data elements to be high risk: 1. OPEID Number 2. CIP Code 3. CIP Year 4. Credential Level 5. Published Program Length Measurement 6. Published Program Length 7. Program Begin Date 8. Program Enrollment Status 9. Program Enrollment Effective Date When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. Condition: Good Samaritan College of Nursing & Health Science did not have effective internal controls over enrollment reporting. Student enrollment information, including enrollment status changes and campus level and program level information, was not reported accurately and/or timely to the NSLDS for certain students. Cause: Good Samaritan College of Nursing & Health Science has been developing and implementing internal controls in response to the prior year finding over enrollment reporting; however, ineffective internal control led to untimely reporting and inaccurate data reported for certain students. Additionally, in the current year, a different matter was noted in that the third-party system that is used to generate reports to validate status changes was not accurate, resulting in certain enrollment status changes not being submitted to NSLDS timely. Effect or potential effect: Lack of internal controls over timely and accurate enrollment reporting resulted in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is important for effective management of the programs. Questioned costs: None. Context: EY selected 61 students from a population of 121 students receiving Pell and Direct Student Loans to test whether the required student enrollment information was accurately and timely reported to NSLDS. For the 61 students selected for testing, we tested 16 attributes for each student, for a total of 976 attributes. Of the 61 students selected, enrollment status was not reported timely, within 60 days, for 4 students receiving direct loans, with reporting to NSLDS ranging from 73 to 187 days. Additionally, of the 61 students selected, for 2 students receiving a direct loan, the correct enrollment status of withdrawn was never reported to NSLDS. As a result of the enrollment status for 6 students being reported late or inaccurately, we noted Campus-Level information was inaccurate in 10 instances for 3 data elements and Program-Level information was inaccurate in 4 instances for 2 data elements. In addition, of the 61 students selected, the program begin date was inaccurately reported for 2 students. Good Samaritan College of Nursing & Health Science has SFA Cluster expenditures of approximately $5.7 million, which makes up 95% of total SFA Cluster expenditures of approximately $6.0 million. Identification as a repeat finding, if applicable: This is a repeat finding for Good Samaritan College of Nursing & Health Science – Findings 2023-010, 2022-005, and 2021-006. An additional internal control matter related to enrollment status is reported in the current year and is a different matter from that reported in the prior years. Recommendation: Good Samaritan College of Nursing & Health Science should refine processes and develop internal controls over enrollment reporting requirements to ensure information used to determine status changes is complete and accurate and that changes in enrollment status are reported timely. Views of responsible officials: Management at Good Samaritan College of Nursing & Health Science agrees with the finding and will work with the student financial aid vendor to ensure all status changes are appropriately captured.

Finding 2024-006 – Allowable Costs/Cost Principles Identification of the federal program: U.S. Department of Treasury Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-through entity: County of Los Angeles Pass-through number: PH-005009 St. Mary Medical Center – Long Beach Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: St. Mary Medical Center – Long Beach did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. Cause: St. Mary Medical Center – Long Beach did not have controls in place to ensure that all timecards were approved. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: No questioned costs. Context: We selected 25 payroll transactions totaling $8,621. Of the 25 transactions selected for testing, 2 timecards with supporting payroll expenditures of $246 were not appropriately approved. We did not note any noncompliance with 2 CFR 200.430. Total payroll expenditures for St. Mary Medical Center – Long Beach were $80,190 and represent approximately 6% of the total program expenditures of approximately $1.4 million. Identification of a repeat finding: This is a not a repeat finding as this program was not previously subject to audit. Recommendation: We recommend management at St. Mary Medical Center – Long Beach execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Additionally, we recommend management execute and retain evidence of its internal controls over the allowability of payroll expenditures. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval was implemented in April 2024.