Audit 353875

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.

U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs, Cash Management, Period of Performance, and Procurement, Suspension and Debarment Type of Finding - Material Noncompliance and Material Weakness in Internal Control over Compliance (Repeat Finding) Condition – The Organization was unable to provide adequate supporting documentation for certain payroll expenditures and drawdowns of federal reimbursement grants. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity must establish and maintain internal controls to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Cause – Due to inadequate controls over document retainage and the changing of third-party payroll providers, the Organization did not have internal controls in place to ensure proper documentation was maintained to support internal controls over the payroll disbursement process involving federal grant funds and for certain drawdowns of these funds. Effect – Material noncompliance with document retainage and support existed and expenditures for reimbursed costs could have potentially been unallowable. Questioned Costs – $1,186,535 (unsupported) Context/Sampling – In a non-statistical sample of 60 out of a population of more than 250, the Organization was not able to provide adequate supporting documentation for all selections to ensure controls were in place over their payroll disbursement process. Additionally, in the testing of all 51 drawdowns, 51 of the selections tested lacked adequate documentation to support the eligible payroll or non-payroll related expenditures. Recommendation - We recommend the Organization implement procedures to ensure its supporting documentation is maintained for all drawdown requests submitted. Management Response to Findings – Management concurs with the finding.

2022-005: U.S. Department of Health and Human Services Health Center Program Cluster- Health Center Program, Assistance Listing No. 93.224 Compliance Requirements: Special Tests and Provisions Type of Finding - Significant Deficiency in Internal Control over Compliance (Repeat Finding) Condition - Proper backup of sliding fee applications and supporting income level documents were not maintained or stored. Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non Federal entity 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. Cause - The Organization did not have internal controls to reasonably ensure compliance. Effect - Patients were potentially incorrectly given or not given proper sliding fee discounts. Context - A non statistical sample of 40 from a population of over 250 encounters was selected for testing. The proper supporting documents were not maintained for 6 encounters tested. Recommendation - We recommend the Organization implement internal controls to reasonably ensure its compliance with the requirements identified in Uniform Guidance. Management Response to Findings – Management concurs with the finding.