Criteria – Uniform Guidance (2 CFR §200.305) requires that non-federal entities establish and maintain written procedures to minimize the time elapsing between the transfer of federal funds from the U.S. Treasury and the disbursement of those funds for allowable program expenditures. In addition, entities must maintain adequate documentation to support all drawdowns and ensure that amounts requested are based on actual, allowable costs incurred. Condition and Description – During our audit, we identified deficiencies in the Organization’s compliance with federal cash management requirements and internal controls over reporting of federal expenditures. Specifically, documentation supporting certain drawdowns of federal funds was not consistently maintained. However, the total drawdowns did not exceed eligible expenses. In addition, we noted timing differences between when expenses were recognized in the financial statements and when related drawdowns were requested and reported to the federal government. These conditions create the risk that federal funds may not be drawn down in alignment with actual expenditures, resulting in temporary over- or under-drawdowns, increasing the likelihood of noncompliance with Uniform Guidance requirements and misstatements of federal program expenditures. Questioned Costs – Unknown. Cause/Effect – Drawdowns were not consistently reconciled to underlying expenses, and supporting documentation was incomplete. Timing differences between expenditures and drawdowns were not addressed, creating the risk of temporary over- or under-drawdowns and noncompliance with federal cash management requirements.
Criteria – Uniform Guidance (2 CFR §200.510(b)) requires auditees to prepare a SEFA that is accurate, complete, and supported by the accounting records. Condition and Description – The Organization did not prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as required by Uniform Guidance. Certain federal awards expended during the year were omitted, and amounts reported did not reconcile to the accounting records, resulting in an incomplete representation of federal expenditures subject to audit. Questioned Costs – Unknown. Cause/Effect –. Controls over SEFA preparation were insufficient to ensure all federal awards were identified and reconciled to the accounting records. As a result, certain expenditures were omitted or misstated, increasing the risk of incomplete or inaccurate reporting under Uniform Guidance.
Criteria – Uniform Guidance (2 CFR §200.512) requires that auditees submit the Single Audit reporting package to the Federal Audit Clearinghouse within nine months after the end of the audit period. Condition and Description – The Organization did not submit its Single Audit reporting package to the Federal Audit Clearinghouse within the nine-month deadline required by Uniform Guidance. The package, which includes the SEFA, Data Collection Form, audit report, summary of prior audit findings, and corrective action plan, was filed after the due date. Questioned Costs – None. Cause/Effect – Due to changes in the accounting personnel during the year, the books were not closed in a timely manner, and various adjustments were made to the general ledger in conjunction of the audit which resulted in delay in completion of the report. Untimely filing resulted in noncompliance with Uniform Guidance reporting requirements and potential federal oversight concerns.
Criteria – The HRSA Compliance Manual requires federally qualified health centers (FQHCs) to establish and maintain a sliding fee discount program to ensure that services are accessible to patients regardless of their ability to pay. Eligibility must be based solely on income and family size, supported by appropriate documentation. Under Uniform Guidance (2 CFR §200.303), non-federal entities must establish and maintain effective internal controls over compliance with federal statutes, regulations, and program requirements. The OMB Compliance Supplement (Part 4, Health Center Program Cluster) further emphasizes that health centers must document income and family size to properly apply sliding fee discounts and must consistently implement the approved discount schedule. Condition and Description – During our testing of compliance with the sliding fee discount program, we identified deficiencies in the application and documentation of the sliding fee discount schedule. Of 10 patient encounters selected for review, 6 patient files did not contain a registration form to support determination of sliding fee eligibility. In addition, although the Organization’s policy requires retention of two paystubs for each patient to verify income, only one paystub was maintained in several patient records. Further, 4 patient files reviewed did not contain documentation of household member information, which is required to calculate family size for eligibility determination. These deficiencies reflect noncompliance with the Organization’s policies and federal program requirements and may result in patients not being charged in accordance with their ability to pay. Questioned Costs – Unknown. Cause/Effect –. The Organization did not obtain or retain adequate documentation of patient income, family size, and registration forms to support eligibility determinations. Without this information, compliance with the sliding fee discount requirements could not be demonstrated, creating the risk that discounts were not applied appropriately and federal program requirements were not met