Audit 350678

Allowable Activities and Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: A grantee's system of internal control should include processes to review after-the-fact interim charges made to a federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice. Condition: During the testing of payroll expenses charged to the grant, it was noted that a formula error resulted in the incorrect calculation of payroll expense for a particular employee. The Organization’s review did not identify that the wages being charged to the grant were inconsistent with the amount actually paid to the identified employee. Questioned Costs: $757. Context: The above condition impacted three (3) of sixty (60) transactions selected for testing, all of which related to the same employee. Cause: The Organization’s process for tracking and aggregating wages charged to the grant was dependent upon a VLOOKUP formula based on the employee’s last name. As a result of there being two employees with the same last name, the formula returned the first such employee from the payroll records. This resulted in the incorrect calculation of payroll expense for the employee selected for testing. Effect: The amount of wages charges to the grant could be different from the actual amount of wages paid to the employee. Repeat Finding: Yes. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a process to review changes to salary and wage information as changes are made or identified.

Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and material weakness in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not assign patients properly to a sliding fee category in their system based on the Organization’s sliding fee scale policy. Information entered into the system did not match the information gathered from patients at the time of the encounter. Questioned Costs: None. Context: Four (4) of forty (40) encounters were not assigned the correct sliding fee category based on the current documentation of family size and income to assess sliding fee discount eligibility. Cause: The information entered into the Organization’s system was not reviewed to verify the proper sliding fee scale was applied for the services performed based on the information gathered from the patient. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all patient information received, prior to it being entered into the system to ensure proper classification of the sliding fee scale. As part of this, the Organization should ensure the accuracy and completeness of the patient information prior to entering into the billing software. Management should work to conduct internal audits of patient visits to determine all required patient information has been obtained and properly entered into the system in accordance with the Organization’s sliding fee scale policy.

Allowable Activities and Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: A grantee's system of internal control should include processes to review after-the-fact interim charges made to a federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice. Condition: During the testing of payroll expenses charged to the grant, it was noted that a formula error resulted in the incorrect calculation of payroll expense for a particular employee. The Organization’s review did not identify that the wages being charged to the grant were inconsistent with the amount actually paid to the identified employee. Questioned Costs: $757. Context: The above condition impacted three (3) of sixty (60) transactions selected for testing, all of which related to the same employee. Cause: The Organization’s process for tracking and aggregating wages charged to the grant was dependent upon a VLOOKUP formula based on the employee’s last name. As a result of there being two employees with the same last name, the formula returned the first such employee from the payroll records. This resulted in the incorrect calculation of payroll expense for the employee selected for testing. Effect: The amount of wages charges to the grant could be different from the actual amount of wages paid to the employee. Repeat Finding: Yes. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a process to review changes to salary and wage information as changes are made or identified.

Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and material weakness in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not assign patients properly to a sliding fee category in their system based on the Organization’s sliding fee scale policy. Information entered into the system did not match the information gathered from patients at the time of the encounter. Questioned Costs: None. Context: Four (4) of forty (40) encounters were not assigned the correct sliding fee category based on the current documentation of family size and income to assess sliding fee discount eligibility. Cause: The information entered into the Organization’s system was not reviewed to verify the proper sliding fee scale was applied for the services performed based on the information gathered from the patient. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all patient information received, prior to it being entered into the system to ensure proper classification of the sliding fee scale. As part of this, the Organization should ensure the accuracy and completeness of the patient information prior to entering into the billing software. Management should work to conduct internal audits of patient visits to determine all required patient information has been obtained and properly entered into the system in accordance with the Organization’s sliding fee scale policy.

Allowable Activities and Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: A grantee's system of internal control should include processes to review after-the-fact interim charges made to a federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice. Condition: During the testing of payroll expenses charged to the grant, it was noted that a formula error resulted in the incorrect calculation of payroll expense for a particular employee. The Organization’s review did not identify that the wages being charged to the grant were inconsistent with the amount actually paid to the identified employee. Questioned Costs: $757. Context: The above condition impacted three (3) of sixty (60) transactions selected for testing, all of which related to the same employee. Cause: The Organization’s process for tracking and aggregating wages charged to the grant was dependent upon a VLOOKUP formula based on the employee’s last name. As a result of there being two employees with the same last name, the formula returned the first such employee from the payroll records. This resulted in the incorrect calculation of payroll expense for the employee selected for testing. Effect: The amount of wages charges to the grant could be different from the actual amount of wages paid to the employee. Repeat Finding: Yes. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a process to review changes to salary and wage information as changes are made or identified.

Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and material weakness in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not assign patients properly to a sliding fee category in their system based on the Organization’s sliding fee scale policy. Information entered into the system did not match the information gathered from patients at the time of the encounter. Questioned Costs: None. Context: Four (4) of forty (40) encounters were not assigned the correct sliding fee category based on the current documentation of family size and income to assess sliding fee discount eligibility. Cause: The information entered into the Organization’s system was not reviewed to verify the proper sliding fee scale was applied for the services performed based on the information gathered from the patient. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all patient information received, prior to it being entered into the system to ensure proper classification of the sliding fee scale. As part of this, the Organization should ensure the accuracy and completeness of the patient information prior to entering into the billing software. Management should work to conduct internal audits of patient visits to determine all required patient information has been obtained and properly entered into the system in accordance with the Organization’s sliding fee scale policy.

Allowable Activities and Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: A grantee's system of internal control should include processes to review after-the-fact interim charges made to a federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice. Condition: During the testing of payroll expenses charged to the grant, it was noted that a formula error resulted in the incorrect calculation of payroll expense for a particular employee. The Organization’s review did not identify that the wages being charged to the grant were inconsistent with the amount actually paid to the identified employee. Questioned Costs: $757. Context: The above condition impacted three (3) of sixty (60) transactions selected for testing, all of which related to the same employee. Cause: The Organization’s process for tracking and aggregating wages charged to the grant was dependent upon a VLOOKUP formula based on the employee’s last name. As a result of there being two employees with the same last name, the formula returned the first such employee from the payroll records. This resulted in the incorrect calculation of payroll expense for the employee selected for testing. Effect: The amount of wages charges to the grant could be different from the actual amount of wages paid to the employee. Repeat Finding: Yes. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a process to review changes to salary and wage information as changes are made or identified.

Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-22 and H80CS00824-23 Award Periods: May 1, 2023 – April 30, 2024, May 1, 2024 – April 30, 2025 Type of Finding: Immaterial noncompliance and material weakness in internal control over compliance Criteria: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not assign patients properly to a sliding fee category in their system based on the Organization’s sliding fee scale policy. Information entered into the system did not match the information gathered from patients at the time of the encounter. Questioned Costs: None. Context: Four (4) of forty (40) encounters were not assigned the correct sliding fee category based on the current documentation of family size and income to assess sliding fee discount eligibility. Cause: The information entered into the Organization’s system was not reviewed to verify the proper sliding fee scale was applied for the services performed based on the information gathered from the patient. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: No. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all patient information received, prior to it being entered into the system to ensure proper classification of the sliding fee scale. As part of this, the Organization should ensure the accuracy and completeness of the patient information prior to entering into the billing software. Management should work to conduct internal audits of patient visits to determine all required patient information has been obtained and properly entered into the system in accordance with the Organization’s sliding fee scale policy.