Audit 404523

Finding Type: Significant deficiency in internal controls over compliance and nonmaterial noncompliance related to Special Tests and Provisions Information on the Federal Program: Program Name: Health Center Program Cluster (93.224/93.527) Federal Awards Project Title: Health Center Program Award Period: February 1, 2024 – January 31, 2025 and February 1, 2025 – January 31, 2026 Award Number: H80CS26642 Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Criteria: In accordance with Section 330(k)(3)(G) of the Public Health Services Act (42 U.S. Code § 254b), as an FQHC, the Organization must have a sliding fee discount program in which patient charges are adjusted based on the patient’s ability to pay. Condition: Through testing a statistically valid sample of 25 individual patient balances, we noted three instances in which the sliding fee discount applied was inconsistent with the Organization’s policy. Two patients did not receive the appropriate discount and one patient received a discount but did not have an active sliding fee application for the service date the sliding fee discount was applied. Cause: The Organization’s discounting process is manual and lacks a formal monitoring procedure to help ensure compliance with the sliding fee discount program, increasing the risk of errors occurring and remaining undetected. Effect: Sliding fee discounts may not be consistently applied in accordance with policy, resulting in potential noncompliance with federal program requirements if errors are not timely identified and corrected. Questioned Costs: None Repeat Finding: No Recommendation: The Organization should establish formal monitoring procedures over the sliding fee discount program. These procedures should include designated responsibility for review, defined frequency and sample sizes of testing, and consideration of system-specific risks, including increased sampling for the Dental system due to its higher level of manual processing. The procedures should also require documentation of review work, timely correction of identified errors, and supervisory oversight to ensure consistent execution. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will develop and implement the recommendations above.

Finding Type: Significant deficiency in internal controls over compliance related to Procurement, Suspension and Debarment Information on the Federal Program: Program Name: Health Center Program Cluster (93.224/93.527) Federal Awards Project Title: Health Center Program Award Period: February 1, 2024 – January 31, 2025 and February 1, 2025 – January 31, 2026 Award Number: H80CS26642 Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Criteria: Under 2 CFR § 200.214 (Suspension and Debarment), non-Federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in Federal programs. To comply with these requirements, entities must implement internal controls reasonably designed to ensure that Federal awards are not used to pay or engage suspended or debarred individuals or entities, including appropriate verification procedures such as screening against the SAM.gov Exclusions List. Condition: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all employees and contractors. SAM.gov checks were performed only for certain clinical providers and were aligned with the Organization’s credentialing cycle (approximately every two years), rather than being performed for all applicable individuals upon hire and/or on a recurring basis. As a result, the Organization’s exclusion screening process was not consistently applied to all individuals whose compensation is charged, in whole or in part, to Federal awards. Cause: The condition resulted from a lack of full understanding of Federal suspension and debarment requirements and the expectation for entity-wide exclusion screening controls under the Uniform Guidance. As a result, the Organization’s policies and procedures did not establish a comprehensive process to ensure SAM.gov exclusion verification was performed for all applicable employees and contractors. Effect: Without appropriately designed and consistently applied exclusion screening procedures, there is an increased risk that Federal funds could be used to compensate suspended or debarred individuals or entities. This could result in noncompliance with Federal award requirements and may result in questioned costs or other Federal award consequences if such individuals or entities were engaged. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that the Organization strengthen its internal controls over compliance with suspension and debarment requirements by implementing formal policies and procedures to help ensure SAM.gov exclusion screenings are performed for all applicable employees and contractors. At a minimum, the Organization should: • Perform SAM.gov exclusion checks at the time of hire or engagement for all employees and contractors whose compensation could possibly be charged to Federal awards; • Establish a defined frequency for ongoing monitoring (e.g., periodic or at least annually) to ensure continued compliance; • Document the results of all exclusion searches and maintain evidence to support compliance with Federal requirements. Additionally, we recommend the Organization evaluate its broader exclusion screening processes to ensure alignment with Federal health care program integrity requirements, including screening against the Office of Inspector General’s List of Excluded Individuals and Entities (LEIE), to further strengthen compliance controls. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Management will implement procedures to ensure SAM.gov exclusion screening is performed for all employees and contractors whose compensation is charged to Federal awards and will strengthen internal controls to support compliance with 2 CFR § 200.214. Management will also evaluate and enhance procedures to incorporate routine screening against the OIG List of Excluded Individuals and Entities (LEIE) as part of its overall compliance process.