Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025
Criteria or specific requirement – Health Centers must prepare and apply a sliding fee
discount schedule that incorporates the provisions of 42 CFR 51c.303e through
56.303g to ensure that amounts owed for health center services by eligible patients
are adjusted (discounted) based on the patient’s ability to pay.
Condition – The audit of the major federal program identified errors in the application of
sliding fee adjustments.
Cause – The sliding fee calculation was improperly set up within the Electronic Health
Record System.
Effect or potential effect – Inaccurate application of sliding fee adjustments may result
in potential noncompliance with program requirements.
Questioned costs – Not applicable
Context – Out of a population of 5,510 sliding fee adjustments, a sample of 25
adjustments were tested. Out of the 25 tested, 5 adjustments were incorrectly
calculated based on the Organization’s sliding fee scales and the patient’s sliding fee
application. A non-statistical sampling methodology was used to select the sample.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend that the Organization perform a review of the
calculation of the sliding fee adjustments within the Electronic Health Record system
to ensure it is properly set up. Additionally, we recommend that a member of
management with an understanding of the Organization’s billing and sliding fee
policies regularly review a sample of sliding fee adjustments in comparison to the
Organization’s sliding fee policy.
Views of responsible officials and planned corrective actions – The sliding fee
adjustment errors resulted from an error in the set up of the automated adjustment
calculation within the Electronic Health Record system. Management has identified the
error with plans to ensure correction within the system. Further, the Organization will
implement a process to periodically review sliding fee adjustments throughout the year
for accuracy.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.
Information on the federal program – Assistance Listing Number 93.224/93.527,
Health Center Program Cluster from the U.S. Department of Health and Human
Services, Federal Award No. 6 H80CS00581 for project period March 1, 2024 through
February 28, 2025.
Criteria or specific requirement – Health Centers must comply with federal reporting
requirements.
Condition – The Organization did not have data to support certain line items reported on
the Uniform Data System (UDS) report filed. The amounts reported within table 5 line
8 column b and b2, table 5 line 10a, column b and b2 were not supportable by
underlying data, and the amounts reported within table 9E line 1g column a, and line
1q column did not agree to underlying supporting data available.
Cause – There was a lack of detailed review of the submitted report by someone with
knowledge of the reporting requirements.
Effect or potential effect – Inaccurate filing of reports may result in the federal program
not being properly monitored, thus resulting in potential noncompliance with program
requirements.
Questioned costs – Not applicable
Context – Out of a population of 1 special report that was required to be submitted
during the year under audit (UDS), we selected this 1 report for testing.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – We recommend management implement an additional level of
review by someone with knowledge of the reporting requirements.
Views of responsible officials and planned corrective actions – To ensure
compliance with federal reporting standards, the Organization will require a secondary
review of all federal reports submitted to granting agencies. The designated secondary
reviewer shall be an individual that has strong knowledge of the reporting
requirements.