Audit 353547

Performance Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare an annual Uniform Data System (UDS) Report required under the Health Center Program authorized by section 330 of the Public Health Service Act. Condition: During our testing, we noted a breakdown in internal controls as the information compiled to prepare the UDS report was not retained internally. Questioned costs: None Context: During our testing of 7 Key Line-Items identified as containing critical information it was noted that the following key line items were not properly supported: 1. Total accrued cost before donations and after allocation of overhead (Table 8A Line 17 Column c) 2. Total accrued medical staff and other medical cost after allocation of overhead excluding medical lab and x-ray cost (Table 8A, Line 1, Column c and Table 8A, Line 3, Column c) 3. Total accrued BPHC COVID-19 Supplemental grant draw-down from January 1 to December 31, of the calendar measurement year (Table 9E, Line 1q, Column a) Cause: There was staff turnover in the financial department during 2023 and the process used by the prior CFO to gather data for UDS reporting was not communicated to the incoming CFO, and therefore tracking of the data was not consistently maintained to support the amounts reported. Effect: The key line-item amounts reported may not be complete and accurate or have documentation readily available to support amounts reported. Repeat Finding: No Recommendation: We recommend that data compiled to prepare the report is saved with a final copy of the report to support the information is complete and accurate. Views of responsible officials: There is no disagreement with the audit finding.

Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay per the grant requirements. Condition: During our testing, we noted a breakdown in internal controls over determining patient eligibility for the sliding fee discount. Questioned costs: None Context: In a sample of 25 patients, 1 patient was noted as eligible per the updated Federal Poverty Guidelines (FPG) and SFDS effective March 2024. This patient did not qualify for a sliding fee discount under the previous SFDS. The slide did not calculate properly resulting in the patient paying more than what they would have had they been assessed the correct sliding fee. Cause: The SFDS updated in March 2024 for annual FPG adjustments was not entered into the client’s billing software; therefore, the slide calculated by the billing software for this patient was based on the previous FPG instead of the updated FPG. The slide determination for this patient would have changed with the new income thresholds per the updated SFDS. Effect: A patient who is eligible for a sliding fee discount under updated FPG did not receive the appropriate discount. Repeat Finding: No Recommendation: We recommend that a test is performed in the billing software annually when the updated SFDS is put into place to ensure that slides are being calculated appropriately at the effective date of the new schedule. Views of responsible officials: There is no disagreement with the audit finding.

Allowable Costs Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: During our testing, we identified a breakdown in internal controls for tracking allowable costs. Two employees’ wages were included in reimbursement support for both the Ohio Department of Health (ODH) Grant and the Health Center Program (HRSA) Grant for some of the same pay periods. . Condition: During our testing, we noted a breakdown in controls where 2 employees whose wages were include in support for reimbursement by one grant were also included in the support for reimbursement by the Health Center Program (HRSA) grant for a few of the same pay periods. Questioned costs: $1,366 Context: In a sample of twenty-seven employees, two employees’ wages were charged and reimbursed by both the ODH and HRSA Grant for the same pay periods. Cause: Employees are assumed to work entirely for the HRSA Grant, and separate time reports are prepared for time worked on the ODH Grant. The reimbursement requests for each grant were prepared and reviewed by different individuals; therefore, there is a risk for error that the same person was charged to both grants was higher. In addition, the timesheets for individuals were not reviewed in the preparation of payroll expenses for the HRSA Grant. Effect: Employee wages for the same period could be reimbursed by two grants. Repeat Finding: No Recommendation: Reimbursement requests for all grants should be reviewed by the same individual for all grants before submission to the grantor to ensure that employees charged to the grants are different, in addition, timesheets should be reviewed during the grant reimbursement process to ensure time supports the specific grant and allowable costs. Views of responsible officials: There is no disagreement with the audit finding.

Performance Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare an annual Uniform Data System (UDS) Report required under the Health Center Program authorized by section 330 of the Public Health Service Act. Condition: During our testing, we noted a breakdown in internal controls as the information compiled to prepare the UDS report was not retained internally. Questioned costs: None Context: During our testing of 7 Key Line-Items identified as containing critical information it was noted that the following key line items were not properly supported: 1. Total accrued cost before donations and after allocation of overhead (Table 8A Line 17 Column c) 2. Total accrued medical staff and other medical cost after allocation of overhead excluding medical lab and x-ray cost (Table 8A, Line 1, Column c and Table 8A, Line 3, Column c) 3. Total accrued BPHC COVID-19 Supplemental grant draw-down from January 1 to December 31, of the calendar measurement year (Table 9E, Line 1q, Column a) Cause: There was staff turnover in the financial department during 2023 and the process used by the prior CFO to gather data for UDS reporting was not communicated to the incoming CFO, and therefore tracking of the data was not consistently maintained to support the amounts reported. Effect: The key line-item amounts reported may not be complete and accurate or have documentation readily available to support amounts reported. Repeat Finding: No Recommendation: We recommend that data compiled to prepare the report is saved with a final copy of the report to support the information is complete and accurate. Views of responsible officials: There is no disagreement with the audit finding.

Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay per the grant requirements. Condition: During our testing, we noted a breakdown in internal controls over determining patient eligibility for the sliding fee discount. Questioned costs: None Context: In a sample of 25 patients, 1 patient was noted as eligible per the updated Federal Poverty Guidelines (FPG) and SFDS effective March 2024. This patient did not qualify for a sliding fee discount under the previous SFDS. The slide did not calculate properly resulting in the patient paying more than what they would have had they been assessed the correct sliding fee. Cause: The SFDS updated in March 2024 for annual FPG adjustments was not entered into the client’s billing software; therefore, the slide calculated by the billing software for this patient was based on the previous FPG instead of the updated FPG. The slide determination for this patient would have changed with the new income thresholds per the updated SFDS. Effect: A patient who is eligible for a sliding fee discount under updated FPG did not receive the appropriate discount. Repeat Finding: No Recommendation: We recommend that a test is performed in the billing software annually when the updated SFDS is put into place to ensure that slides are being calculated appropriately at the effective date of the new schedule. Views of responsible officials: There is no disagreement with the audit finding.

Allowable Costs Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: During our testing, we identified a breakdown in internal controls for tracking allowable costs. Two employees’ wages were included in reimbursement support for both the Ohio Department of Health (ODH) Grant and the Health Center Program (HRSA) Grant for some of the same pay periods. . Condition: During our testing, we noted a breakdown in controls where 2 employees whose wages were include in support for reimbursement by one grant were also included in the support for reimbursement by the Health Center Program (HRSA) grant for a few of the same pay periods. Questioned costs: $1,366 Context: In a sample of twenty-seven employees, two employees’ wages were charged and reimbursed by both the ODH and HRSA Grant for the same pay periods. Cause: Employees are assumed to work entirely for the HRSA Grant, and separate time reports are prepared for time worked on the ODH Grant. The reimbursement requests for each grant were prepared and reviewed by different individuals; therefore, there is a risk for error that the same person was charged to both grants was higher. In addition, the timesheets for individuals were not reviewed in the preparation of payroll expenses for the HRSA Grant. Effect: Employee wages for the same period could be reimbursed by two grants. Repeat Finding: No Recommendation: Reimbursement requests for all grants should be reviewed by the same individual for all grants before submission to the grantor to ensure that employees charged to the grants are different, in addition, timesheets should be reviewed during the grant reimbursement process to ensure time supports the specific grant and allowable costs. Views of responsible officials: There is no disagreement with the audit finding.

Performance Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare an annual Uniform Data System (UDS) Report required under the Health Center Program authorized by section 330 of the Public Health Service Act. Condition: During our testing, we noted a breakdown in internal controls as the information compiled to prepare the UDS report was not retained internally. Questioned costs: None Context: During our testing of 7 Key Line-Items identified as containing critical information it was noted that the following key line items were not properly supported: 1. Total accrued cost before donations and after allocation of overhead (Table 8A Line 17 Column c) 2. Total accrued medical staff and other medical cost after allocation of overhead excluding medical lab and x-ray cost (Table 8A, Line 1, Column c and Table 8A, Line 3, Column c) 3. Total accrued BPHC COVID-19 Supplemental grant draw-down from January 1 to December 31, of the calendar measurement year (Table 9E, Line 1q, Column a) Cause: There was staff turnover in the financial department during 2023 and the process used by the prior CFO to gather data for UDS reporting was not communicated to the incoming CFO, and therefore tracking of the data was not consistently maintained to support the amounts reported. Effect: The key line-item amounts reported may not be complete and accurate or have documentation readily available to support amounts reported. Repeat Finding: No Recommendation: We recommend that data compiled to prepare the report is saved with a final copy of the report to support the information is complete and accurate. Views of responsible officials: There is no disagreement with the audit finding.

Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay per the grant requirements. Condition: During our testing, we noted a breakdown in internal controls over determining patient eligibility for the sliding fee discount. Questioned costs: None Context: In a sample of 25 patients, 1 patient was noted as eligible per the updated Federal Poverty Guidelines (FPG) and SFDS effective March 2024. This patient did not qualify for a sliding fee discount under the previous SFDS. The slide did not calculate properly resulting in the patient paying more than what they would have had they been assessed the correct sliding fee. Cause: The SFDS updated in March 2024 for annual FPG adjustments was not entered into the client’s billing software; therefore, the slide calculated by the billing software for this patient was based on the previous FPG instead of the updated FPG. The slide determination for this patient would have changed with the new income thresholds per the updated SFDS. Effect: A patient who is eligible for a sliding fee discount under updated FPG did not receive the appropriate discount. Repeat Finding: No Recommendation: We recommend that a test is performed in the billing software annually when the updated SFDS is put into place to ensure that slides are being calculated appropriately at the effective date of the new schedule. Views of responsible officials: There is no disagreement with the audit finding.

Allowable Costs Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: During our testing, we identified a breakdown in internal controls for tracking allowable costs. Two employees’ wages were included in reimbursement support for both the Ohio Department of Health (ODH) Grant and the Health Center Program (HRSA) Grant for some of the same pay periods. . Condition: During our testing, we noted a breakdown in controls where 2 employees whose wages were include in support for reimbursement by one grant were also included in the support for reimbursement by the Health Center Program (HRSA) grant for a few of the same pay periods. Questioned costs: $1,366 Context: In a sample of twenty-seven employees, two employees’ wages were charged and reimbursed by both the ODH and HRSA Grant for the same pay periods. Cause: Employees are assumed to work entirely for the HRSA Grant, and separate time reports are prepared for time worked on the ODH Grant. The reimbursement requests for each grant were prepared and reviewed by different individuals; therefore, there is a risk for error that the same person was charged to both grants was higher. In addition, the timesheets for individuals were not reviewed in the preparation of payroll expenses for the HRSA Grant. Effect: Employee wages for the same period could be reimbursed by two grants. Repeat Finding: No Recommendation: Reimbursement requests for all grants should be reviewed by the same individual for all grants before submission to the grantor to ensure that employees charged to the grants are different, in addition, timesheets should be reviewed during the grant reimbursement process to ensure time supports the specific grant and allowable costs. Views of responsible officials: There is no disagreement with the audit finding.

Performance Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare an annual Uniform Data System (UDS) Report required under the Health Center Program authorized by section 330 of the Public Health Service Act. Condition: During our testing, we noted a breakdown in internal controls as the information compiled to prepare the UDS report was not retained internally. Questioned costs: None Context: During our testing of 7 Key Line-Items identified as containing critical information it was noted that the following key line items were not properly supported: 1. Total accrued cost before donations and after allocation of overhead (Table 8A Line 17 Column c) 2. Total accrued medical staff and other medical cost after allocation of overhead excluding medical lab and x-ray cost (Table 8A, Line 1, Column c and Table 8A, Line 3, Column c) 3. Total accrued BPHC COVID-19 Supplemental grant draw-down from January 1 to December 31, of the calendar measurement year (Table 9E, Line 1q, Column a) Cause: There was staff turnover in the financial department during 2023 and the process used by the prior CFO to gather data for UDS reporting was not communicated to the incoming CFO, and therefore tracking of the data was not consistently maintained to support the amounts reported. Effect: The key line-item amounts reported may not be complete and accurate or have documentation readily available to support amounts reported. Repeat Finding: No Recommendation: We recommend that data compiled to prepare the report is saved with a final copy of the report to support the information is complete and accurate. Views of responsible officials: There is no disagreement with the audit finding.

Special Tests and Provisions Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay per the grant requirements. Condition: During our testing, we noted a breakdown in internal controls over determining patient eligibility for the sliding fee discount. Questioned costs: None Context: In a sample of 25 patients, 1 patient was noted as eligible per the updated Federal Poverty Guidelines (FPG) and SFDS effective March 2024. This patient did not qualify for a sliding fee discount under the previous SFDS. The slide did not calculate properly resulting in the patient paying more than what they would have had they been assessed the correct sliding fee. Cause: The SFDS updated in March 2024 for annual FPG adjustments was not entered into the client’s billing software; therefore, the slide calculated by the billing software for this patient was based on the previous FPG instead of the updated FPG. The slide determination for this patient would have changed with the new income thresholds per the updated SFDS. Effect: A patient who is eligible for a sliding fee discount under updated FPG did not receive the appropriate discount. Repeat Finding: No Recommendation: We recommend that a test is performed in the billing software annually when the updated SFDS is put into place to ensure that slides are being calculated appropriately at the effective date of the new schedule. Views of responsible officials: There is no disagreement with the audit finding.

Allowable Costs Federal agency: U.S. Department of Health and Human Services Federal program title: Health Center Program Cluster (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H8026575-2023, H8026575-2024, H8G48725-2022 Award Period: December 2022 through February 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: During our testing, we identified a breakdown in internal controls for tracking allowable costs. Two employees’ wages were included in reimbursement support for both the Ohio Department of Health (ODH) Grant and the Health Center Program (HRSA) Grant for some of the same pay periods. . Condition: During our testing, we noted a breakdown in controls where 2 employees whose wages were include in support for reimbursement by one grant were also included in the support for reimbursement by the Health Center Program (HRSA) grant for a few of the same pay periods. Questioned costs: $1,366 Context: In a sample of twenty-seven employees, two employees’ wages were charged and reimbursed by both the ODH and HRSA Grant for the same pay periods. Cause: Employees are assumed to work entirely for the HRSA Grant, and separate time reports are prepared for time worked on the ODH Grant. The reimbursement requests for each grant were prepared and reviewed by different individuals; therefore, there is a risk for error that the same person was charged to both grants was higher. In addition, the timesheets for individuals were not reviewed in the preparation of payroll expenses for the HRSA Grant. Effect: Employee wages for the same period could be reimbursed by two grants. Repeat Finding: No Recommendation: Reimbursement requests for all grants should be reviewed by the same individual for all grants before submission to the grantor to ensure that employees charged to the grants are different, in addition, timesheets should be reviewed during the grant reimbursement process to ensure time supports the specific grant and allowable costs. Views of responsible officials: There is no disagreement with the audit finding.