Audit 404425

Criteria or Specific Requirement According to §200.303 Internal Controls of 2 CFR Part 200, the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and Context During our testing, we noted the Organization was unable to provide documentation to support management review and approval of the eight drawdown requests selected for testing prior to the drawdowns occurring. Effect The incorrect amount of federal funds may be requested to be drawn down. Questioned Costs None identified. Cause Management Oversight. Drawdowns were prepared and submitted without secondary review. Recommendation We recommend the Organization to review internal controls in regards to the approval of federal fund drawdown requests. Views of Responsible Officials The Organization is in agreement with finding. The control issue was due to turnover in finance staff during fiscal year 2025. Under the direction of the Organization’s new CFO, the following revised procedures for cash management have been implemented for fiscal year 2026: • Payroll Documentation: A staff accountant or the controller will compile payroll expense details along with supporting documentation for each drawdown. • Review and Approval: This documentation is submitted to the CFO for review prior to any fund transfer. • Drawdown Execution: Upon approval, the CFO will initiate the drawdown from PMS. • Frequency: Drawdowns are processed on a biweekly basis and reflect expenses from the preceding payroll cycle. Upon completion of the drawdown, the CFO will save a copy of the drawdown request to the internal drive. • This drawdown receipt is reviewed by a second staff member, either the controller or senior accountant. • Drawdowns are also reviewed during monthly bank reconciliations.

Criteria or Specific Requirement Per Title 42 Chapter 1 Subchapter D Section 51c303(f), “Health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges designed to cover their reasonable costs of operation. 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 and Context During our testing of sixty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that did not have a sliding fee discount application on file to verify the sliding fee discount amount and two visits where the patient received an incorrect sliding fee adjustment based on their income and family size. Effect Potential that a patient would not receive the appropriate sliding fee discount or may receive a discount when they have not applied for one. Questioned Costs None identified. Cause Clerical error in which either the sliding fee rate was miscalculated, the incorrect sliding fee rate was selected and applied, or the sliding fee application was not scanned into the patients file due to lack of an oversight process in place. Recommendation We recommend the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Views of Responsible Officials These errors are due to incorrect slide percentage amounts being put into eCW. There is also a known issue within eCW where the eCW changes the slide amount to either 100% or a different slide than was entered. The Organization has found a work around so that the Organization can fix this issue before claims are adjusted. Billing will start reviewing slide documents prior to applying slide to make sure that the percentage entered into eCW is correct for income/family size. These will also be reviewed by the front desk manager and lead patient service representative.