Audit 363221

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 001 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/24 - 12/31/24 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition and Context The Organization began allocating direct salaries and benefits prior to the awards period of performance start date. The Organization allocated expenditures based on the payroll paid date, rather than the date the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of performance start date was $21,049. Effect Potential that costs will be charged to the grant outside of the period of performance. Questioned Costs $21,049 Cause The Organization allocated payroll expenditures based on the paid date, rather than the incurred date. Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.Views of Responsible Officials The Organization corrected the period of performance finding prior to the 2024 audit being completed and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff have been properly trained to review all grants to ensure compliance with all grant regulations. This grant can be used for staffing costs and upon identification of this issue we have corrected the allocations to the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff are being trained to ensure they are following grant guidelines.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.

2024 – 002 Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Award Period: 9/21/23 - 6/30/25 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension & debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None Cause The debarment check for one vendor was not completed until after the invoice was paid. Recommendation We recommend that the Organization implement a process to ensure suspension and debarment checks are performed and documentation is retained to show that the checks are occurring prior to entering into transactions with vendors.Views of Responsible Officials The Organization has internal staffing challenges within the accounting department in 2024 resulting in turnover. The Organization has a process in place to check vendors against the OIG exclusion list when the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied the wire payment one day prior to the Organization running the check against the exclusion list. The Organization was under the impression that the vendor would not execute the wire on that date. The Organization did perform a suspension and debarment check subsequent to the payment being made, and no findings were found for the vendor. We believe the payment was expedited by the vendor due to their implementation timeline and feel this is an isolated one-time event.