Audit 413863

FY End
2025-12-31
Total Expended
$69.46M
Findings
3
Programs
35
Organization: Montefiore Health System, Inc. (NY)
Year: 2025 Accepted: 2026-09-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1238997 2025-001 Material Weakness Yes N
1238998 2025-001 Material Weakness Yes N
1238999 2025-002 Material Weakness Yes I

Programs

ALN Program Spent Major Findings
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $36.01M Yes 0
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $6.72M Yes 0
93.224 HEALTH CENTER PROGRAM $3.82M Yes 1
93.086 HEALTHY MARRIAGE PROMOTION AND RESPONSIBLE FATHERHOOD GRANTS $2.95M Yes 0
93.493 CONGRESSIONAL DIRECTIVES $2.54M Yes 1
93.378 INTEGRATED CARE FOR KIDS MODEL $1.87M Yes 0
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $1.86M Yes 0
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $1.73M Yes 0
93.778 GRANTS TO STATES FOR MEDICAID $1.73M Yes 0
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $975,141 Yes 0
93.399 CANCER CONTROL $893,379 Yes 0
97.039 HAZARD MITIGATION GRANT $889,479 Yes 0
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $882,188 Yes 1
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $818,096 Yes 0
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $768,274 Yes 0
93.087 ENHANCE SAFETY OF CHILDREN AFFECTED BY SUBSTANCE ABUSE $718,461 Yes 0
93.924 RYAN WHITE HIV/AIDS DENTAL REIMBURSEMENT AND COMMUNITY BASED DENTAL PARTNERSHIP GRANTS $446,410 Yes 0
84.268 FEDERAL DIRECT STUDENT LOANS $418,310 Yes 0
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $394,783 Yes 0
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA — RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B $383,491 Yes 0
93.899 MINORITY HIV/AIDS FUND (MHAF) $316,288 Yes 0
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $305,962 Yes 0
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $303,217 Yes 0
84.063 FEDERAL PELL GRANT PROGRAM $245,216 Yes 0
93.395 CANCER TREATMENT RESEARCH $170,046 Yes 0
10.331 GUS SCHUMACHER NUTRITION INCENTIVE PROGRAM $139,219 Yes 0
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $117,760 Yes 0
93.889 COVID-19 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $102,000 Yes 0
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $60,254 Yes 0
93.837 CARDIOVASCULAR DISEASES RESEARCH $42,307 Yes 0
93.365 SICKLE CELL TREATMENT DEMONSTRATION PROGRAM $32,382 Yes 0
93.080 BLOOD DISORDER PROGRAM: PREVENTION, SURVEILLANCE, AND RESEARCH $17,143 Yes 0
93.334 THE HEALTHY BRAIN INITIATIVE: TECHNICAL ASSISTANCE TO IMPLEMENT PUBLIC HEALTH ACTIONS RELATED TO COGNITIVE HEALTH, COGNITIVE IMPAIRMENT, AND CAREGIVING AT THE STATE AND LOCAL LEVELS $11,081 Yes 0
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $4,843 Yes 0
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1,001 Yes 0

Contacts

Name Title Type
FP1VD1HU5HV7 James Geraghty Auditee
7184303255 Jessica Liconti Auditor
No contacts on file

Notes to SEFA

During the year ended December 31, 2025, the Health System participated in the New York State Department of Health WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) through the receipt and distribution of food vouchers. The U.S. Department of Agriculture has determined that such WIC food vouchers are considered “property in lieu of money” and, therefore, should be reported as federal awards received by the Health System. See the Notes to the SEFA for chart/table. The total amount reported as federal awards above, represents the value of food checks redeemed and administrative costs in the amount of $5,989,354, for the year ended December 31, 2025. As state funds are commingled with the federal funds received by New York State, percentages (96% for administrative costs and 100% for the value of checks redeemed for Federal fiscal year ended 2025) were applied to determine the total amount of federal funds to be reported above. These percentages were supplied by the New York State Department of Health.
During the year ended December 31, 2025, the Health System processed $702,811 in new loans under the Federal Direct Student Loans Program (Assistance Listing No. 84.268). Since this program is administered by outside financial institutions, new loans made in the year ended December 31, 2025 relating to this program are considered current period federal expenditures, whereas the outstanding balances are not. The new loans made in the year ended December 31, 2025 are reported in the Schedule.

Finding Details

Finding 2025-001 – N: Special Tests and Provisions Information on the Federal Program: Grantor: United States Department of Health and Human Services Program Name: Health Center Program Cluster Assistance Listing Numbers: 93.224 – Health Center Program; 93.527 – Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR), Part 200.303 of the Uniform Guidance states the following regarding internal control, “The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per 42 CFR sections 51c.303(e), (f), and (g) and 42 CFR sections 56.303(e), (f), and (g), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay as defined by these subsections. Condition: Montefiore Health System, Inc. (the Health System) was unable to demonstrate that internal controls were operating effectively throughout the audit period to ensure the proper application of its sliding fee discount schedule (SFDS). During testing, three patients were charged self-pay balances when, based on the applicable sliding fee discount schedule, those charges should have been discounted. The exceptions occurred prior to the implementation of corrective actions associated with the prior-year finding. Management implemented enhanced controls effective October 1, 2025; however, the identified exceptions demonstrate that controls were not operating effectively during a portion of the audit period. Cause: Corrective actions associated with the prior-year finding were not fully implemented until October 1, 2025. As a result, controls designed to ensure the consistent and accurate application of the sliding fee discount schedule were not operating effectively during a portion of the audit period, resulting in instances where eligible patients were assessed self-pay balances that should have been discounted. Effect or Potential Effect: As a result of the control deficiency, eligible patients were charged self-pay balances that exceeded amounts permitted under the Health System's sliding fee discount schedule. Although the exceptions identified were limited to transactions occurring prior to the implementation of corrective actions effective October 1, 2025, failure to effectively apply the SFDS could result in eligible patients being charged incorrect amounts and increase the risk of noncompliance with Federal program requirements. Questioned Costs: None noted. Amounts charged to patients do not impact expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA); therefore, no questioned costs were identified. Context: We tested 60 compliance samples from a population of 31,357 transactions for compliance with the Health Center Program Cluster special test and provision related to sliding fee discount schedule requirements. Three exceptions were identified in which patients were charged self-pay balances that should have been reduced based on the applicable sliding fee discount schedule. All three exceptions occurred during the first nine months of the audit period, prior to management's implementation of corrective actions effective October 1, 2025. Identification as a repeat finding: Repeat Finding 2024-001 Recommendation: We recommend management continue to monitor the effectiveness of the corrective actions implemented on October 1, 2025 and ensure controls operate consistently to verify that sliding fee discount determinations are supported, documented, and applied accurately in accordance with Federal requirements and organizational policy. View of responsible officials: Management concurs with the audit finding and will continue to monitor the effectiveness of the corrective actions implemented October 1, 2025. The total of noted exceptions was determined to be de minimis (less than $50). Standardized procedures have been implemented to strengthen patient screening and enrollment, including controls to ensure the timely collection and documentation of income and family size.
Finding 2025-002 – I. Procurement and Suspension and Debarment Information on the Federal Program: Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Program Name: Congressional Directives Assistance Listing Numbers: 93.493 Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D 200.320 – Procurement methods – requires entities to maintain documented procurement procedures and appropriate supporting documentation for procurement methods, including noncompetitive procurements. Purchases below the simple acquisition threshold, but above the micro-purchase threshold, require price and rate quotations to be obtained from an adequate number of qualified sources. Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 - Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: The Health System did not retain documentation demonstrating either (1) competitive bidding was performed or (2) the justification and circumstances supporting the use of a noncompetitive procurement method for equipment, installation and broadband services purchased under the grant. The procurement transactions reviewed exceeded the micro-purchase threshold; however, no supporting competitive procurement or sole-source documentation was available for audit inspection. The Health System has an established process to monitor vendor suspension and debarment requirements. Management’s process includes suspension and debarment evaluations on all new vendors prior to entering into any business relationship. The Health System utilized a third party to perform monthly suspension and debarment reviews; however, vendors associated with the program were not included in the listings provided to the third party for review. As a result, the Health System could not demonstrate that required suspension and debarment procedures had been performed for applicable vendors. Cause: Controls over the retention and maintenance of procurement documentation were not operating effectively to ensure that competitive procurement activities or sole-source justifications were documented and retained in accordance with Federal requirements. Controls over the identification and submission of vendors subject to suspension and debarment review were not operating effectively to ensure all applicable program vendors were included in the monthly review process performed by the third party. Effect or potential effect: Failure to maintain procurement documentation supporting competition or sole-source justification may result in noncompliance with Federal procurement requirements and limits the Health System's ability to demonstrate that contracts were awarded in accordance with Federal regulations. Failure to perform and document required suspension and debarment procedures increases the risk that the Health System could enter into a covered transaction with a suspended, debarred, or otherwise excluded party, resulting in noncompliance with Federal requirements. Questioned costs: Questioned costs totaled $2,299,513 and represent procurement transactions exceeding the micro-purchase threshold for which competitive procurement or sole-source documentation was not available for audit inspection. Although the costs are questioned due to the lack of required procurement documentation, the audit team noted the costs appear allowable. No questioned costs were noted for suspension and debarment. Audit procedures performed by the audit team determined that none of the vendors tested were suspended or debarred. Context: The population consisted of 20 procurement transactions. We selected a sample of 5 procurement transactions for testing and identified exceptions in all 5 items tested. For each transaction selected, the Health System was unable to provide documentation demonstrating that competitive bidding occurred or documentation supporting the circumstances that would allow for the use of a noncompetitive procurement method at the time the procurement occurred. The population consisted of 8 vendors associated with the Congressional Directives program. We selected a sample of 5 vendors for testing and identified exceptions for all 5 vendors. Specifically, several of the vendors selected for testing did not appear on a sample of 6 monthly vendor listings provided to the third party responsible for performing suspension and debarment reviews. As a result, the Health System could not demonstrate that the required suspension and debarment procedures had been performed for those vendors. Although these vendors were not subjected to the Health System's suspension and debarment review process, our independent verification procedures noted that none of the vendors tested were suspended or debarred. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: The Health System should strengthen its internal controls over procurement and suspension and debarment compliance to ensure: (1) procurement files contain and retain documentation supporting competitive procurement procedures or noncompetitive procurement justifications, as applicable; and (2) all vendors subject to Federal suspension and debarment requirements are identified, included in the review process, and appropriately documented. Views of Responsible Officials: Management agrees with the findings. The Health System has established procurement policies and procedures; however, the purchases identified in the audit were not consistently processed through the established procurement review process, and the required supporting documentation was not retained. The purchases involved IT equipment, installation, and broadband services necessary for the project. Management believes the vendor selections were supportable as sole-source procurements based on technical compatibility, integration with existing IT infrastructure, continuity of implementation and support, and specialized vendor capabilities. Management determined that the associated costs were allowable. Corrective action will focus on reinforcing departmental compliance with the existing procurement policy, requiring procurement’s involvement before vendor engagement, and ensuring that competitive bidding documentation or an approved sole-source justification is retained for all federally funded purchases. Although the Health System has an established suspension and debarment screening process, certain vendors associated with the Federal program were not included in the screening population. Management will implement a documented reconciliation of federally funded vendors to the screening population, including supervisory review and resolution of any exceptions, to ensure that all applicable vendors are screened and evidence of the screening is retained. No questioned costs were identified, and subsequent to the transaction, management verified that none of the vendors tested were suspended or debarred at the time of the transactions.