Audit 403385

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award No. 5 H80CS00681-23-07, June 1, 2024 – May 31, 2025 Award No. 6 H80CS00681-24-04, June 1, 2025 – May 31, 2026 Award No. 5 H8KCS49728-02-00, September 1, 2024 - August 3, 2025 Criteria or Specific Requirement – Cash Management – 2 CFR 200.305 Condition – The Organization’s internal controls over the cash drawdown process did not minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes by the Organization. Cause – The Organization did not comply with their federal cash drawdown policy or federal grant cash management requirements. Effect or potential effect– Grant funds were drawn down sooner than administratively necessary. Questioned Costs – None Context – The Organization did not follow their process of determining whether sufficient grant expenditures had been incurred and disbursed prior to drawing down grant funds. Grant funds were drawn down prior to disbursements of expenditures within the grant period for $707,934 for two out of eleven draws during the fiscal year ended June 30, 2025. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should ensure procedures are followed to prevent cash draws from being drawn down prior to disbursement of allowable expenditures. Views of Responsible Officials and Planned Corrective Actions – Management Response - Management concurs with the auditor's finding. The Organization acknowledges the cash drawdown process was not operating effectively to minimize the time lapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes to the Organization. Corrective Action Taken - Designated Crossing Healthcare staff will submit cash draw down requests no more than 5 business days prior to the anticipated pay date for the pay period claimed. Management has developed a dedicated schedule listing Organization pay periods, pay dates, appropriate fund draw dates, and funding draw amounts. Completion Date - Completed 5/7/2026 Responsible Contact Person - Julie Brilley, CEO

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award No. 5 H80CS00681-23-07, June 1, 2024 – May 31, 2025 Award No. 6 H80CS00681-24-04, June 1, 2025 – May 31, 2026 Criteria or Specific Requirement –– Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect– Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned Costs – None Context – A selection of 25 encounters were testing out of the total population of 81,898 encounters. The sampling methodology used is not and is not intended to be statistically valid. Eleven encounters received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their family size and household income documentation. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented and reviewed to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions – Management Response - Management concurs with the auditor's finding. The Organization acknowledges that patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization's policy. Corrective Action Taken - (1) Crossing has implemented a billing workflow to automatically apply sliding fee scale discounts to all eligible self-pay accounts during the billing process, eliminating manual charge adjustments and improving consistency with established guidelines. (2) All billing staff have received retraining on the correct manual posting procedures for sliding fee scale adjustments after insurance payments, ensuring compliance with patient income verification and applicable percentage guidelines. (3) We will continue ongoing monitoring and review of accounts receiving sliding fee scale adjustments to ensure accurate and compliant application of the approved discount and percentages. Completion Date - Completed 4/1/26 Responsible Contact Person - Margret Guy, Director of Revenue; Julie Brilley, CEO

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award No. 5 H80CS00681-23-07, June 1, 2024 – May 31, 2025 Award No. 6 H80CS00681-24-04, June 1, 2025 – May 31, 2026 Criteria or Specific Requirement – Reporting – 2 CFR 200.329 Condition – The Organization is required to prepare and submit an annual Uniform Data System (UDS) for each calendar year for the Health Center Program Cluster. This report is to be prepared using accurate financial information. Cause – The Organization was unable to provide supporting documentation that agreed to the line items tested on the report. Effect or potential effect– Potential errors were made on the annual UDS report. Questioned Costs – None Context – The Organization’s annual UDS report was selected for testing. Of the ten inputs tested, four exceptions were noted related to the annual UDS report. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should revise polices and procedures over federal reporting to ensure reports are prepared using accurate information and supporting documentation for federal grant reports should be maintained. Views of Responsible Officials and Planned Corrective Actions – Management Response - Management concurs with the auditor's finding. The Organization acknowledges that a mistake was made on Table 9E-Other Revenue, where grant income, from the Early Childhood Development (ECD) grant, was listed in the incorrect location. The ECD grant should have been listed under Federal Grants: UHI Grant Revenue. Additionally, the Organization's UDS preparer, completed a transposition error when entering a salary amount in Table 8A. Corrective Action Planned - Management has engaged with an independent 3rd party accounting firm to review current processes, assist with strengthening internal controls and month-end/year-end closing procedures, and provide assistance in completing the Organization's annual UDS report. Completion Date - Completed 1/1/2026 Responsible Contact Person - Margret Guy, Director of Revenue; Julie Brilley, CEO