2024-001: Federal Financial Reporting (FFR)
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. In addition, the federal financial reporting (FFR) instructions specify the requirements for accurate reporting.
Condition: During our testing, there were multiple inaccuracies identified on the FFR submitted to the funder. Specifically, the Organization was not accurately reporting the federal share of expenditures, its non-federal share requirement and reporting on its program income on its quarterly FFR for the period ending June 30, 2024.
Questioned Costs: None
Context: The Notice of Awards specified the federal and recipient share of expenditures, and use of program income. This information is required to be reported on the Organization’s federal financial report, but amounts were not reported correctly based on the cumulative award totals.
Cause: The Organization was not fully aware of the FFR reporting requirements. It also appears the Organization was completing the FFR based on the cash basis rather than the accrual basis as indicated on the FFR.
Effect: The Organization did not report the correct amounts for federal share of expenditures, recipient share of expenditures or program income on its required FFR reporting.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001.
Recommendation: We recommend management review the FFR instructions and develop procedures to ensure the required reporting submitted to the funder is complete and accurate. Additionally, systems should be put in place to both track and report its progress on the non-federal share requirement and any program income.
Views of Responsible Official: There is no disagreement with the audit finding.
2024-001: Federal Financial Reporting (FFR)
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. In addition, the federal financial reporting (FFR) instructions specify the requirements for accurate reporting.
Condition: During our testing, there were multiple inaccuracies identified on the FFR submitted to the funder. Specifically, the Organization was not accurately reporting the federal share of expenditures, its non-federal share requirement and reporting on its program income on its quarterly FFR for the period ending June 30, 2024.
Questioned Costs: None
Context: The Notice of Awards specified the federal and recipient share of expenditures, and use of program income. This information is required to be reported on the Organization’s federal financial report, but amounts were not reported correctly based on the cumulative award totals.
Cause: The Organization was not fully aware of the FFR reporting requirements. It also appears the Organization was completing the FFR based on the cash basis rather than the accrual basis as indicated on the FFR.
Effect: The Organization did not report the correct amounts for federal share of expenditures, recipient share of expenditures or program income on its required FFR reporting.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001.
Recommendation: We recommend management review the FFR instructions and develop procedures to ensure the required reporting submitted to the funder is complete and accurate. Additionally, systems should be put in place to both track and report its progress on the non-federal share requirement and any program income.
Views of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: In accordance with the HHS Office of Population Affairs Title X Program Handbook, Chapter 3: Program Expectations, family planning service providers must prepare and apply a sliding fee discount schedule so that amounts owed for family planning services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 59.5(a), family planning service providers must have a schedule of fees or payments for the provision of their services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the federal poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS), which considers the individual's annual income and household size.
Condition: The Organization determines the sliding fee discount charged to the patients based on their annual gross income and household size which is documented on the patient intake form. During our testing of patient files, we noted the 5 out of 40 encounters selected did not show evidence of control over the processing of the patient intake forms. Specifically, the missing control procedure was the lack of documented review by clinic personnel of the patient's annual income and household size that was collected on the patient intake form and entered into the patient billing system.
Questioned Costs: None
Context: Patient intake forms are signed by both the patient and clinic personnel. This form is filled out by the patient indicating use or no use of insurance, that they are responsible for the charges, etc. This form also serves as verification of the patient’s annual income and household size which is then entered into the patient billing system to calculate billing/ eligibility for assistance, as applicable.
Cause: The lack of evidence of signed intake forms by clinic personnel did not support controls over the verification of patient income and household size that was entered into the patient billing system. This was caused by inadequate oversight and evidence to support review was performed.
Effect: Patients could have been given an improper sliding fee discount without documentation to support that the patient qualified based on their income and household size.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002.
Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements.
Views of Responsible Official: Management agrees with the finding. Management will review its patient intake policies and procedures.
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: In accordance with the HHS Office of Population Affairs Title X Program Handbook, Chapter 3: Program Expectations, family planning service providers must prepare and apply a sliding fee discount schedule so that amounts owed for family planning services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 59.5(a), family planning service providers must have a schedule of fees or payments for the provision of their services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the federal poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS), which considers the individual's annual income and household size.
Condition: The Organization determines the sliding fee discount charged to the patients based on their annual gross income and household size which is documented on the patient intake form. During our testing of patient files, we noted the 5 out of 40 encounters selected did not show evidence of control over the processing of the patient intake forms. Specifically, the missing control procedure was the lack of documented review by clinic personnel of the patient's annual income and household size that was collected on the patient intake form and entered into the patient billing system.
Questioned Costs: None
Context: Patient intake forms are signed by both the patient and clinic personnel. This form is filled out by the patient indicating use or no use of insurance, that they are responsible for the charges, etc. This form also serves as verification of the patient’s annual income and household size which is then entered into the patient billing system to calculate billing/ eligibility for assistance, as applicable.
Cause: The lack of evidence of signed intake forms by clinic personnel did not support controls over the verification of patient income and household size that was entered into the patient billing system. This was caused by inadequate oversight and evidence to support review was performed.
Effect: Patients could have been given an improper sliding fee discount without documentation to support that the patient qualified based on their income and household size.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002.
Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements.
Views of Responsible Official: Management agrees with the finding. Management will review its patient intake policies and procedures.
Federal Agency: Department of Health and Human Services
Federal Program: Teenage Pregnancy Prevention Program
Federal Assistance Listing Number(s): 93.297
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: According to 2 CFR § 200.309, costs must be incurred during the period of performance specified in the federal award. Costs incurred outside this period are unallowable unless explicitly authorized by the awarding agency.
Condition: During testing, it was noted that costs totaling $6,933 were charged to the award outside the designated period of performance. Specifically, these costs were incurred before the start date of the award.
Questioned Costs: $6,933
Context: Of the costs tested it was identified five of eight transactions sampled were incurred prior to the period of performance start date listed in the notification of award. The total dollar amount was $6,933 and related to payroll incurred prior to the start date of the award but paid after the start date.
Cause: The Organization did not have adequate internal controls to ensure that costs were only charged within the period of performance. There was a lack of communication between the finance department and program managers regarding the start date of the award.
Effect: Questioned costs were identified.
Repeat Finding: No
Recommendation: We recommend the Organization implement stronger internal controls to monitor the period of performance on its federal awards. This includes regular training for staff on compliance requirements and establishing clear communication channels between finance and program departments.
Views of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services
Federal Program: Teenage Pregnancy Prevention Program
Federal Assistance Listing Number(s): 93.297
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: As a pass-through entity, the Organization has certain requirements listed in 2 CFR § 200.332 related to funds passed through to subrecipients, including required information in subaward agreements. There are also requirements related to ongoing monitoring of the subrecipient.
Condition: Based on testing, it was identified one subaward agreement lacked key details, such as acknowledgement of federal funding and applicable compliance requirements under the subaward. Furthermore, the Organization did not obtain or review the most recent single audit reports and there was also no documented review performed to substantiate the timely completion of the annual desk audit, as required under the Organization’s subrecipient monitoring policy.
Questioned Costs: None
Context: Two subrecipients were tested as part of audit procedures performed, noting that the most recent audit had not been obtained for one subrecipient. We also noted missing or unclear documentation around the oversight procedures, specifically documentation to support the annual desk audit was performed as outlined in the Organization's policies.
Cause: The Organization did not have proper policies and procedures in place. Additionally, certain policies outlined in the fiscal policies manual were not adequately documented. This occurred during a time of organizational re-structuring and turnover which may have led to the lapses in controls over monitoring.
Effect: Inadequate monitoring procedures may not detect subrecipient noncompliance on a timely basis.
Repeat Finding: No
Recommendation: We recommend the Organization enhance its policies and procedures to ensure adequate oversight and monitoring of subrecipients throughout the subaward period, including reviewing audit reports on a timely basis, actively following up with subrecipients on any audit findings to verify corrective action is being taken, and clearly documenting an annual desk review. Additionally, the Organization should ensure it provides subrecipients with clear information on the federal award, including the federal assistance listing number, as well as the federal requirements applicable under the agreement. This information should be written into the subaward agreement and signed by both parties.
Views of Responsible Official: There is no disagreement with the audit finding.
2024-001: Federal Financial Reporting (FFR)
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. In addition, the federal financial reporting (FFR) instructions specify the requirements for accurate reporting.
Condition: During our testing, there were multiple inaccuracies identified on the FFR submitted to the funder. Specifically, the Organization was not accurately reporting the federal share of expenditures, its non-federal share requirement and reporting on its program income on its quarterly FFR for the period ending June 30, 2024.
Questioned Costs: None
Context: The Notice of Awards specified the federal and recipient share of expenditures, and use of program income. This information is required to be reported on the Organization’s federal financial report, but amounts were not reported correctly based on the cumulative award totals.
Cause: The Organization was not fully aware of the FFR reporting requirements. It also appears the Organization was completing the FFR based on the cash basis rather than the accrual basis as indicated on the FFR.
Effect: The Organization did not report the correct amounts for federal share of expenditures, recipient share of expenditures or program income on its required FFR reporting.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001.
Recommendation: We recommend management review the FFR instructions and develop procedures to ensure the required reporting submitted to the funder is complete and accurate. Additionally, systems should be put in place to both track and report its progress on the non-federal share requirement and any program income.
Views of Responsible Official: There is no disagreement with the audit finding.
2024-001: Federal Financial Reporting (FFR)
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. In addition, the federal financial reporting (FFR) instructions specify the requirements for accurate reporting.
Condition: During our testing, there were multiple inaccuracies identified on the FFR submitted to the funder. Specifically, the Organization was not accurately reporting the federal share of expenditures, its non-federal share requirement and reporting on its program income on its quarterly FFR for the period ending June 30, 2024.
Questioned Costs: None
Context: The Notice of Awards specified the federal and recipient share of expenditures, and use of program income. This information is required to be reported on the Organization’s federal financial report, but amounts were not reported correctly based on the cumulative award totals.
Cause: The Organization was not fully aware of the FFR reporting requirements. It also appears the Organization was completing the FFR based on the cash basis rather than the accrual basis as indicated on the FFR.
Effect: The Organization did not report the correct amounts for federal share of expenditures, recipient share of expenditures or program income on its required FFR reporting.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001.
Recommendation: We recommend management review the FFR instructions and develop procedures to ensure the required reporting submitted to the funder is complete and accurate. Additionally, systems should be put in place to both track and report its progress on the non-federal share requirement and any program income.
Views of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: In accordance with the HHS Office of Population Affairs Title X Program Handbook, Chapter 3: Program Expectations, family planning service providers must prepare and apply a sliding fee discount schedule so that amounts owed for family planning services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 59.5(a), family planning service providers must have a schedule of fees or payments for the provision of their services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the federal poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS), which considers the individual's annual income and household size.
Condition: The Organization determines the sliding fee discount charged to the patients based on their annual gross income and household size which is documented on the patient intake form. During our testing of patient files, we noted the 5 out of 40 encounters selected did not show evidence of control over the processing of the patient intake forms. Specifically, the missing control procedure was the lack of documented review by clinic personnel of the patient's annual income and household size that was collected on the patient intake form and entered into the patient billing system.
Questioned Costs: None
Context: Patient intake forms are signed by both the patient and clinic personnel. This form is filled out by the patient indicating use or no use of insurance, that they are responsible for the charges, etc. This form also serves as verification of the patient’s annual income and household size which is then entered into the patient billing system to calculate billing/ eligibility for assistance, as applicable.
Cause: The lack of evidence of signed intake forms by clinic personnel did not support controls over the verification of patient income and household size that was entered into the patient billing system. This was caused by inadequate oversight and evidence to support review was performed.
Effect: Patients could have been given an improper sliding fee discount without documentation to support that the patient qualified based on their income and household size.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002.
Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements.
Views of Responsible Official: Management agrees with the finding. Management will review its patient intake policies and procedures.
Federal Agency: Department of Health and Human Services
Federal Program: Family Planning Services – Title X
Federal Assistance Listing Number(s): 93.217
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: In accordance with the HHS Office of Population Affairs Title X Program Handbook, Chapter 3: Program Expectations, family planning service providers must prepare and apply a sliding fee discount schedule so that amounts owed for family planning services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 59.5(a), family planning service providers must have a schedule of fees or payments for the provision of their services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the federal poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS), which considers the individual's annual income and household size.
Condition: The Organization determines the sliding fee discount charged to the patients based on their annual gross income and household size which is documented on the patient intake form. During our testing of patient files, we noted the 5 out of 40 encounters selected did not show evidence of control over the processing of the patient intake forms. Specifically, the missing control procedure was the lack of documented review by clinic personnel of the patient's annual income and household size that was collected on the patient intake form and entered into the patient billing system.
Questioned Costs: None
Context: Patient intake forms are signed by both the patient and clinic personnel. This form is filled out by the patient indicating use or no use of insurance, that they are responsible for the charges, etc. This form also serves as verification of the patient’s annual income and household size which is then entered into the patient billing system to calculate billing/ eligibility for assistance, as applicable.
Cause: The lack of evidence of signed intake forms by clinic personnel did not support controls over the verification of patient income and household size that was entered into the patient billing system. This was caused by inadequate oversight and evidence to support review was performed.
Effect: Patients could have been given an improper sliding fee discount without documentation to support that the patient qualified based on their income and household size.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002.
Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements.
Views of Responsible Official: Management agrees with the finding. Management will review its patient intake policies and procedures.
Federal Agency: Department of Health and Human Services
Federal Program: Teenage Pregnancy Prevention Program
Federal Assistance Listing Number(s): 93.297
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: According to 2 CFR § 200.309, costs must be incurred during the period of performance specified in the federal award. Costs incurred outside this period are unallowable unless explicitly authorized by the awarding agency.
Condition: During testing, it was noted that costs totaling $6,933 were charged to the award outside the designated period of performance. Specifically, these costs were incurred before the start date of the award.
Questioned Costs: $6,933
Context: Of the costs tested it was identified five of eight transactions sampled were incurred prior to the period of performance start date listed in the notification of award. The total dollar amount was $6,933 and related to payroll incurred prior to the start date of the award but paid after the start date.
Cause: The Organization did not have adequate internal controls to ensure that costs were only charged within the period of performance. There was a lack of communication between the finance department and program managers regarding the start date of the award.
Effect: Questioned costs were identified.
Repeat Finding: No
Recommendation: We recommend the Organization implement stronger internal controls to monitor the period of performance on its federal awards. This includes regular training for staff on compliance requirements and establishing clear communication channels between finance and program departments.
Views of Responsible Official: There is no disagreement with the audit finding.
Federal Agency: Department of Health and Human Services
Federal Program: Teenage Pregnancy Prevention Program
Federal Assistance Listing Number(s): 93.297
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance – Other Matters
Criteria or Specific Requirement: As a pass-through entity, the Organization has certain requirements listed in 2 CFR § 200.332 related to funds passed through to subrecipients, including required information in subaward agreements. There are also requirements related to ongoing monitoring of the subrecipient.
Condition: Based on testing, it was identified one subaward agreement lacked key details, such as acknowledgement of federal funding and applicable compliance requirements under the subaward. Furthermore, the Organization did not obtain or review the most recent single audit reports and there was also no documented review performed to substantiate the timely completion of the annual desk audit, as required under the Organization’s subrecipient monitoring policy.
Questioned Costs: None
Context: Two subrecipients were tested as part of audit procedures performed, noting that the most recent audit had not been obtained for one subrecipient. We also noted missing or unclear documentation around the oversight procedures, specifically documentation to support the annual desk audit was performed as outlined in the Organization's policies.
Cause: The Organization did not have proper policies and procedures in place. Additionally, certain policies outlined in the fiscal policies manual were not adequately documented. This occurred during a time of organizational re-structuring and turnover which may have led to the lapses in controls over monitoring.
Effect: Inadequate monitoring procedures may not detect subrecipient noncompliance on a timely basis.
Repeat Finding: No
Recommendation: We recommend the Organization enhance its policies and procedures to ensure adequate oversight and monitoring of subrecipients throughout the subaward period, including reviewing audit reports on a timely basis, actively following up with subrecipients on any audit findings to verify corrective action is being taken, and clearly documenting an annual desk review. Additionally, the Organization should ensure it provides subrecipients with clear information on the federal award, including the federal assistance listing number, as well as the federal requirements applicable under the agreement. This information should be written into the subaward agreement and signed by both parties.
Views of Responsible Official: There is no disagreement with the audit finding.