Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Material noncompliance and Material weakness in internal control over compliance
Criteria:
Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)).
Condition:
Legacy incorrectly assessed and/or applied the sliding fee discount to patient encounters during the year.
Questioned Costs:
None.
Context:
Five (5) of sixty (60) encounters selected for testing.
Cause:
Unknown.
Effect:
Patients are not charged according to Legacy's sliding fee scale and their ability to pay.
Repeat Finding:
Yes.
Prior Year Finding:
2023-002.
Recommendation:
Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
One (1) of two (2) transactions selected for testing within 21.027 and three (3) of three (3) transactions selected for testing within 93.224/93.527.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2023-005.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-004 – Allowable Costs
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
§ 200.303(a) indicates non-federal entities must establish, document 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition:
Lack of supporting documentation demonstrating management's review and approval of costs prior to being charged to the grant and drawn down.
Questioned Costs:
None.
Context:
This condition impact all of the payroll transactions selected for testing.
Cause:
Unknown
Effect:
Incorrect payroll costs could be charged to the grant.
Repeat Finding:
No.
Recommendation:
We recommend the Organization maintain documentation demonstrating that the existing payroll review and approval process in place is functioning.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-005 – Suspension and debarment
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
One (1) of two (2) vendors tested within 21.027 and two (2) of two (2) vendors within 93.224/93.527.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had been checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2023-006.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
One (1) of two (2) transactions selected for testing within 21.027 and three (3) of three (3) transactions selected for testing within 93.224/93.527.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2023-005.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-005 – Suspension and debarment
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
One (1) of two (2) vendors tested within 21.027 and two (2) of two (2) vendors within 93.224/93.527.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had been checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2023-006.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023;
Type of Finding: Material noncompliance and Material weakness in internal control over compliance
Criteria:
Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)).
Condition:
Legacy incorrectly assessed and/or applied the sliding fee discount to patient encounters during the year.
Questioned Costs:
None.
Context:
Five (5) of sixty (60) encounters selected for testing.
Cause:
Unknown.
Effect:
Patients are not charged according to Legacy's sliding fee scale and their ability to pay.
Repeat Finding:
Yes.
Prior Year Finding:
2023-002.
Recommendation:
Management should consider increasing the frequency of its self-reviews of patient encounters or expanding its sample sizes in addition to providing additional training for front desk staff regarding the collection and verification of patient information for each patient.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
One (1) of two (2) transactions selected for testing within 21.027 and three (3) of three (3) transactions selected for testing within 93.224/93.527.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2023-005.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-004 – Allowable Costs
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Number: 93.224/93.527
Federal Award Identification
Number: L2C42352-01-00
Award Periods: July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
§ 200.303(a) indicates non-federal entities must establish, document 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition:
Lack of supporting documentation demonstrating management's review and approval of costs prior to being charged to the grant and drawn down.
Questioned Costs:
None.
Context:
This condition impact all of the payroll transactions selected for testing.
Cause:
Unknown
Effect:
Incorrect payroll costs could be charged to the grant.
Repeat Finding:
No.
Recommendation:
We recommend the Organization maintain documentation demonstrating that the existing payroll review and approval process in place is functioning.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-005 – Suspension and debarment
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
One (1) of two (2) vendors tested within 21.027 and two (2) of two (2) vendors within 93.224/93.527.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had been checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2023-006.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023.
Type of Finding: Material weakness in internal control over compliance
Criteria:
2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c).
Condition:
Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing.
Questioned Costs:
Unknown.
Context:
One (1) of two (2) transactions selected for testing within 21.027 and three (3) of three (3) transactions selected for testing within 93.224/93.527.
Cause:
Legacy did not maintain appropriate documentation based on the method of procurement utilized.
Effect:
Legacy may inadvertently select vendors without regard to fair competition and cost analysis.
Repeat Finding:
Yes.
Prior Year Finding:
2023-005.
Recommendation:
We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list.
Views of Responsible Officials:
There is no disagreement with the audit finding.
Finding 2024-005 – Suspension and debarment
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster
Assistance Listing Number: 21.027; 93.224/93.527
Pass-Through Entity: Cook County Department of Public Health, N/A
Pass-Through Number: None; N/A
Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023;
Type of Finding: Significant deficiency in internal control over compliance
Criteria:
2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition:
Legacy did not document that sam.gov was checked prior to entering into a contract with a vendor.
Questioned Costs:
None.
Context:
One (1) of two (2) vendors tested within 21.027 and two (2) of two (2) vendors within 93.224/93.527.
Cause:
Legacy did not create and maintain documentation showing that suspension and debarment had been checked prior to engaging a vendor.
Effect:
Contracted vendors may be ineligible to receive federal dollars for services performed.
Repeat Finding:
Yes.
Prior Year Finding:
2023-006.
Recommendation:
We recommend that Legacy check, and document, the use of Sam.gov to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to entering into a contract.
Views of Responsible Officials:
There is no disagreement with the audit finding.