Audit 345566

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay.” The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.