Audit 400452

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Non-Compliance) Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We selected a non-statistical sample of 60 patients who received services during the audit period, out of a population of approximately 5,300 patients, and noted the Health Board did not maintain Tribal enrollment documentation for 1 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is a repeat finding from the prior year. See prior year finding 2024-001. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.

Finding 2025-002 – Suspension and Debarment (Significant Deficiency in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions more than $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies identified in the suspension and debarment process, include the following: • The program had 18 covered transactions over $25,000. From this full population, we randomly selected a sample of four covered transactions subject to suspension and debarment requirements. For one of the items tested the Health Board could not provide the required evidence that they performed a suspension and debarment search. For all of the items tested the Health Board could not provide the required evidence that there was a bid process or sole source justification used to select the vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is a repeat finding. See prior year finding 2024-002. Recommendation – The Health Board has adequate policies in place, so we recommend that departments overseeing programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Criteria – In accordance with the Health and Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount scheduled so that amounts owed for health center services by eligible patients are adjusted based on the patients’ ability to pay. Condition and Context – We selected 40 patient visits out of the entire population of patients who may be eligible to receive benefits under the program during the fiscal year ended September 30, 2025. The Health Board did not retain underlying data in accordance with policy to support the sliding fee scale discount based on the patients’ family size or income. Additionally, the Health Board had instances in which discounts were not applied accurately based on the underlying support that was provided by the patient. In 6 out of the 40 samples tested, the Health Board was unable to locate underlying support required per their policy. Cause – The program did not follow the Health Board’s established policies to appropriately apply the sliding fee discounts under Uniform Guidance. Effect – Certain patients may have been billed amounts less than the amounts defined by the sliding fee discount schedule. Questioned Costs – Not applicable. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that further processes and training be put in place to ensure that the sliding fee scale is accurately applied to all qualifying program participants. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.