2023 – 006 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Title 42 Chapter 1 Subchapter D Section 51C303(f) and (g), health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operations. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay. Condition: During our audit testing surrounding the sliding fee discount policy, we noted two instances where an error was made in the sliding fee determination, or insufficient documentation was retained to support adjustment calculation. Questioned costs: None. Context: 1 out of 25 sliding fee adjustments tested was not calculated properly in accordance with the Organization's policy. For this individual the sliding fee adjustment category was determined incorrectly, and a larger adjustment was provided than what the correct determination would have provided. For 1 out of 25 sliding fee adjustments tested, the sliding fee application was not able to be provided, so there was not sufficient documentation to support the sliding fee determination. Cause: Manual errors and insufficient review or oversight in the sliding fee adjustment calculation process. Effect: A patient paid the incorrect amount for an encounter as the sliding fee adjustment had been calculated incorrectly. For another patient encounter, the Organization is not able to provide sufficient supporting organization for the sliding fee adjustment determined. No specific instances of noncompliance with the grant requirements were identified, although there were instances of noncompliance with the Organization's own policies. The lack of internal controls over these compliance requirements, however, creates a risk for noncompliance. Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. View of responsible officials: No disagreement with the finding. Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications.
2023 – 007 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: In our audit testing around payroll expenditures, the Organization was not able to provide supporting documentation of the internal control process occurring where supervisors review and approve employee timesheets with each payroll. Questioned costs: None. Context: The Organization changed its payroll system during the year, and historic timesheet data, including documentation of approval on timesheets, was not retained in the transition. Therefore in our testing of 38 payroll transactions, we were able to get support for the underlying expenses to support an eligible grant expenditure, but not able to obtain support of the internal control occurring of supervisor approval of time. Cause: Payroll system transition resulted in loss of historic documentation on time sheets and supervisor approval. Effect: Without retained documentation, the Organization is not able to support the existence of internal controls in place. Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial reporting. View of responsible officials: No disagreement with the finding. Management will retain timesheet documentation moving forward to support control process in place.
2023 – 008 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: The Organization did not have sufficient internal control process or review in place over required reporting for federal programs. There was no documentation retained of review occurring before submission of reports. Errors were identified in key line items tested in the UDS report filed for 2022 during the fiscal year 2023. Questioned costs: None. Context: While the Organization has historically had a review process over required federal program reporting, there was no documentation of that review occurring for the reports tested, including FFR reports and UDS report for the community health center grants. For the UDS report, due to an error in supporting schedules, amounts reported in Table 9E, lines 1g and 1q were overstated. There was turnover in key finance positions at the Organization, where historical segregation of duties between preparer and reviewer was not always possible. Cause: Turnover in personnel at the Organization likely led to lapses in review processes that had been in place historically. The lack of detailed review likely resulted in the errors identified in UDS reporting. Effect: Without sufficient review processes in place, there is greater risk of noncompliance or errors in required reporting under federal programs. In the case of the UDS reporting, certain line items were misreported due to errors in supporting spreadsheets. Repeat Finding: The finding is a repeat of finding in the immediately prior year. Prior year finding number was 2022-006. Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/approval occurrence. View of responsible officials: No disagreement with the finding. Management will implement a formal review process for reporting and retain documentation of review. This has been incorporated in subsequent reporting years.
2023 – 006 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Title 42 Chapter 1 Subchapter D Section 51C303(f) and (g), health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operations. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay. Condition: During our audit testing surrounding the sliding fee discount policy, we noted two instances where an error was made in the sliding fee determination, or insufficient documentation was retained to support adjustment calculation. Questioned costs: None. Context: 1 out of 25 sliding fee adjustments tested was not calculated properly in accordance with the Organization's policy. For this individual the sliding fee adjustment category was determined incorrectly, and a larger adjustment was provided than what the correct determination would have provided. For 1 out of 25 sliding fee adjustments tested, the sliding fee application was not able to be provided, so there was not sufficient documentation to support the sliding fee determination. Cause: Manual errors and insufficient review or oversight in the sliding fee adjustment calculation process. Effect: A patient paid the incorrect amount for an encounter as the sliding fee adjustment had been calculated incorrectly. For another patient encounter, the Organization is not able to provide sufficient supporting organization for the sliding fee adjustment determined. No specific instances of noncompliance with the grant requirements were identified, although there were instances of noncompliance with the Organization's own policies. The lack of internal controls over these compliance requirements, however, creates a risk for noncompliance. Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. View of responsible officials: No disagreement with the finding. Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications.
2023 – 007 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: In our audit testing around payroll expenditures, the Organization was not able to provide supporting documentation of the internal control process occurring where supervisors review and approve employee timesheets with each payroll. Questioned costs: None. Context: The Organization changed its payroll system during the year, and historic timesheet data, including documentation of approval on timesheets, was not retained in the transition. Therefore in our testing of 38 payroll transactions, we were able to get support for the underlying expenses to support an eligible grant expenditure, but not able to obtain support of the internal control occurring of supervisor approval of time. Cause: Payroll system transition resulted in loss of historic documentation on time sheets and supervisor approval. Effect: Without retained documentation, the Organization is not able to support the existence of internal controls in place. Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial reporting. View of responsible officials: No disagreement with the finding. Management will retain timesheet documentation moving forward to support control process in place.
2023 – 008 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: The Organization did not have sufficient internal control process or review in place over required reporting for federal programs. There was no documentation retained of review occurring before submission of reports. Errors were identified in key line items tested in the UDS report filed for 2022 during the fiscal year 2023. Questioned costs: None. Context: While the Organization has historically had a review process over required federal program reporting, there was no documentation of that review occurring for the reports tested, including FFR reports and UDS report for the community health center grants. For the UDS report, due to an error in supporting schedules, amounts reported in Table 9E, lines 1g and 1q were overstated. There was turnover in key finance positions at the Organization, where historical segregation of duties between preparer and reviewer was not always possible. Cause: Turnover in personnel at the Organization likely led to lapses in review processes that had been in place historically. The lack of detailed review likely resulted in the errors identified in UDS reporting. Effect: Without sufficient review processes in place, there is greater risk of noncompliance or errors in required reporting under federal programs. In the case of the UDS reporting, certain line items were misreported due to errors in supporting spreadsheets. Repeat Finding: The finding is a repeat of finding in the immediately prior year. Prior year finding number was 2022-006. Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/approval occurrence. View of responsible officials: No disagreement with the finding. Management will implement a formal review process for reporting and retain documentation of review. This has been incorporated in subsequent reporting years.
2023 – 006 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Title 42 Chapter 1 Subchapter D Section 51C303(f) and (g), health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operations. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay. Condition: During our audit testing surrounding the sliding fee discount policy, we noted two instances where an error was made in the sliding fee determination, or insufficient documentation was retained to support adjustment calculation. Questioned costs: None. Context: 1 out of 25 sliding fee adjustments tested was not calculated properly in accordance with the Organization's policy. For this individual the sliding fee adjustment category was determined incorrectly, and a larger adjustment was provided than what the correct determination would have provided. For 1 out of 25 sliding fee adjustments tested, the sliding fee application was not able to be provided, so there was not sufficient documentation to support the sliding fee determination. Cause: Manual errors and insufficient review or oversight in the sliding fee adjustment calculation process. Effect: A patient paid the incorrect amount for an encounter as the sliding fee adjustment had been calculated incorrectly. For another patient encounter, the Organization is not able to provide sufficient supporting organization for the sliding fee adjustment determined. No specific instances of noncompliance with the grant requirements were identified, although there were instances of noncompliance with the Organization's own policies. The lack of internal controls over these compliance requirements, however, creates a risk for noncompliance. Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. View of responsible officials: No disagreement with the finding. Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications.
2023 – 007 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: In our audit testing around payroll expenditures, the Organization was not able to provide supporting documentation of the internal control process occurring where supervisors review and approve employee timesheets with each payroll. Questioned costs: None. Context: The Organization changed its payroll system during the year, and historic timesheet data, including documentation of approval on timesheets, was not retained in the transition. Therefore in our testing of 38 payroll transactions, we were able to get support for the underlying expenses to support an eligible grant expenditure, but not able to obtain support of the internal control occurring of supervisor approval of time. Cause: Payroll system transition resulted in loss of historic documentation on time sheets and supervisor approval. Effect: Without retained documentation, the Organization is not able to support the existence of internal controls in place. Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial reporting. View of responsible officials: No disagreement with the finding. Management will retain timesheet documentation moving forward to support control process in place.
2023 – 008 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: The Organization did not have sufficient internal control process or review in place over required reporting for federal programs. There was no documentation retained of review occurring before submission of reports. Errors were identified in key line items tested in the UDS report filed for 2022 during the fiscal year 2023. Questioned costs: None. Context: While the Organization has historically had a review process over required federal program reporting, there was no documentation of that review occurring for the reports tested, including FFR reports and UDS report for the community health center grants. For the UDS report, due to an error in supporting schedules, amounts reported in Table 9E, lines 1g and 1q were overstated. There was turnover in key finance positions at the Organization, where historical segregation of duties between preparer and reviewer was not always possible. Cause: Turnover in personnel at the Organization likely led to lapses in review processes that had been in place historically. The lack of detailed review likely resulted in the errors identified in UDS reporting. Effect: Without sufficient review processes in place, there is greater risk of noncompliance or errors in required reporting under federal programs. In the case of the UDS reporting, certain line items were misreported due to errors in supporting spreadsheets. Repeat Finding: The finding is a repeat of finding in the immediately prior year. Prior year finding number was 2022-006. Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/approval occurrence. View of responsible officials: No disagreement with the finding. Management will implement a formal review process for reporting and retain documentation of review. This has been incorporated in subsequent reporting years.
2023 – 006 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Title 42 Chapter 1 Subchapter D Section 51C303(f) and (g), health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operations. They are also required to have a corresponding schedule of discounts applied and adjusted on the basis of the patient's ability to pay. Condition: During our audit testing surrounding the sliding fee discount policy, we noted two instances where an error was made in the sliding fee determination, or insufficient documentation was retained to support adjustment calculation. Questioned costs: None. Context: 1 out of 25 sliding fee adjustments tested was not calculated properly in accordance with the Organization's policy. For this individual the sliding fee adjustment category was determined incorrectly, and a larger adjustment was provided than what the correct determination would have provided. For 1 out of 25 sliding fee adjustments tested, the sliding fee application was not able to be provided, so there was not sufficient documentation to support the sliding fee determination. Cause: Manual errors and insufficient review or oversight in the sliding fee adjustment calculation process. Effect: A patient paid the incorrect amount for an encounter as the sliding fee adjustment had been calculated incorrectly. For another patient encounter, the Organization is not able to provide sufficient supporting organization for the sliding fee adjustment determined. No specific instances of noncompliance with the grant requirements were identified, although there were instances of noncompliance with the Organization's own policies. The lack of internal controls over these compliance requirements, however, creates a risk for noncompliance. Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. View of responsible officials: No disagreement with the finding. Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications.
2023 – 007 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: In our audit testing around payroll expenditures, the Organization was not able to provide supporting documentation of the internal control process occurring where supervisors review and approve employee timesheets with each payroll. Questioned costs: None. Context: The Organization changed its payroll system during the year, and historic timesheet data, including documentation of approval on timesheets, was not retained in the transition. Therefore in our testing of 38 payroll transactions, we were able to get support for the underlying expenses to support an eligible grant expenditure, but not able to obtain support of the internal control occurring of supervisor approval of time. Cause: Payroll system transition resulted in loss of historic documentation on time sheets and supervisor approval. Effect: Without retained documentation, the Organization is not able to support the existence of internal controls in place. Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial reporting. View of responsible officials: No disagreement with the finding. Management will retain timesheet documentation moving forward to support control process in place.
2023 – 008 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Numbers: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/22 – 1/31/23, 2/1/23 – 1/31/24, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states 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. Condition: The Organization did not have sufficient internal control process or review in place over required reporting for federal programs. There was no documentation retained of review occurring before submission of reports. Errors were identified in key line items tested in the UDS report filed for 2022 during the fiscal year 2023. Questioned costs: None. Context: While the Organization has historically had a review process over required federal program reporting, there was no documentation of that review occurring for the reports tested, including FFR reports and UDS report for the community health center grants. For the UDS report, due to an error in supporting schedules, amounts reported in Table 9E, lines 1g and 1q were overstated. There was turnover in key finance positions at the Organization, where historical segregation of duties between preparer and reviewer was not always possible. Cause: Turnover in personnel at the Organization likely led to lapses in review processes that had been in place historically. The lack of detailed review likely resulted in the errors identified in UDS reporting. Effect: Without sufficient review processes in place, there is greater risk of noncompliance or errors in required reporting under federal programs. In the case of the UDS reporting, certain line items were misreported due to errors in supporting spreadsheets. Repeat Finding: The finding is a repeat of finding in the immediately prior year. Prior year finding number was 2022-006. Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/approval occurrence. View of responsible officials: No disagreement with the finding. Management will implement a formal review process for reporting and retain documentation of review. This has been incorporated in subsequent reporting years.