Audit 342156

2024 – 001 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two visits didn’t have a sliding fee discount application on file to verify the sliding fee discount amount. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not scanned into the patients file due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials The Organization corrected the claims on October 17, 2024 to reverse the sliding fee discounts that were provided without proper sliding fee application support and billing staff will work with the patients to attempt to collect the balance. The Organization has made changes to its workflow and provided education to staff instructing them the importance of sliding fee applications and only applying the correct sliding fee discount amount when proper documentation support exists.

2024 – 001 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two visits didn’t have a sliding fee discount application on file to verify the sliding fee discount amount. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not scanned into the patients file due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials The Organization corrected the claims on October 17, 2024 to reverse the sliding fee discounts that were provided without proper sliding fee application support and billing staff will work with the patients to attempt to collect the balance. The Organization has made changes to its workflow and provided education to staff instructing them the importance of sliding fee applications and only applying the correct sliding fee discount amount when proper documentation support exists.

2024 – 002 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exception:  For one of the procurement transactions tested the Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). Effect The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Questioned Costs None identified. Cause The Organization lacked a process to ensure all supporting procurement documentation is retained to support the procurement method used. Recommendation We recommend the Organization retain all documentation and support to show that the procurement policy was followed. Views of Responsible Officials The Organization maintains procurement policies and procedures, including sole source award procedures, that closely track federal procurement regulations. However, the Organization was unable to locate the sole source documentation prepared at the time of the award in 2021. This is likely attributable to management turnover, along with the operational impact of the COVID Public Health Emergency in effect at that time. The Organization will schedule training for managers on procurement, sole source awards, and document retention. In addition, the Finance Department will review its forms and workflows to ensure filing accuracy and strengthen procurement controls.

2024 – 002 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exception:  For one of the procurement transactions tested the Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). Effect The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Questioned Costs None identified. Cause The Organization lacked a process to ensure all supporting procurement documentation is retained to support the procurement method used. Recommendation We recommend the Organization retain all documentation and support to show that the procurement policy was followed. Views of Responsible Officials The Organization maintains procurement policies and procedures, including sole source award procedures, that closely track federal procurement regulations. However, the Organization was unable to locate the sole source documentation prepared at the time of the award in 2021. This is likely attributable to management turnover, along with the operational impact of the COVID Public Health Emergency in effect at that time. The Organization will schedule training for managers on procurement, sole source awards, and document retention. In addition, the Finance Department will review its forms and workflows to ensure filing accuracy and strengthen procurement controls.

2024 – 001 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two visits didn’t have a sliding fee discount application on file to verify the sliding fee discount amount. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not scanned into the patients file due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials The Organization corrected the claims on October 17, 2024 to reverse the sliding fee discounts that were provided without proper sliding fee application support and billing staff will work with the patients to attempt to collect the balance. The Organization has made changes to its workflow and provided education to staff instructing them the importance of sliding fee applications and only applying the correct sliding fee discount amount when proper documentation support exists.

2024 – 001 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient’s ability to pay.” Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified two visits didn’t have a sliding fee discount application on file to verify the sliding fee discount amount. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which the sliding fee application was not scanned into the patients file due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials The Organization corrected the claims on October 17, 2024 to reverse the sliding fee discounts that were provided without proper sliding fee application support and billing staff will work with the patients to attempt to collect the balance. The Organization has made changes to its workflow and provided education to staff instructing them the importance of sliding fee applications and only applying the correct sliding fee discount amount when proper documentation support exists.

2024 – 002 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exception:  For one of the procurement transactions tested the Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). Effect The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Questioned Costs None identified. Cause The Organization lacked a process to ensure all supporting procurement documentation is retained to support the procurement method used. Recommendation We recommend the Organization retain all documentation and support to show that the procurement policy was followed. Views of Responsible Officials The Organization maintains procurement policies and procedures, including sole source award procedures, that closely track federal procurement regulations. However, the Organization was unable to locate the sole source documentation prepared at the time of the award in 2021. This is likely attributable to management turnover, along with the operational impact of the COVID Public Health Emergency in effect at that time. The Organization will schedule training for managers on procurement, sole source awards, and document retention. In addition, the Finance Department will review its forms and workflows to ensure filing accuracy and strengthen procurement controls.

2024 – 002 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 7/1/23 - 6/30/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exception:  For one of the procurement transactions tested the Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). Effect The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Questioned Costs None identified. Cause The Organization lacked a process to ensure all supporting procurement documentation is retained to support the procurement method used. Recommendation We recommend the Organization retain all documentation and support to show that the procurement policy was followed. Views of Responsible Officials The Organization maintains procurement policies and procedures, including sole source award procedures, that closely track federal procurement regulations. However, the Organization was unable to locate the sole source documentation prepared at the time of the award in 2021. This is likely attributable to management turnover, along with the operational impact of the COVID Public Health Emergency in effect at that time. The Organization will schedule training for managers on procurement, sole source awards, and document retention. In addition, the Finance Department will review its forms and workflows to ensure filing accuracy and strengthen procurement controls.