2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.
2022 ? 002 Special Tests: Application of Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance 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.? Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 002 Special Tests: Application of Sliding Fee Discount (Continued) Condition and Context During our testing of forty sliding fee discounts for health center patients qualifying for reduced charge visits, we identified one visit that received the incorrect sliding fee discount. We also identified one visit where the Organization was not able to locate the sliding fee discount application. Effect Potential that a patient would not receive the appropriate sliding fee discount. Questioned Costs None identified. Cause Clerical error in which the incorrect discount was applied 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. We also recommend the Organization put a process in place to make sure all applications are retained. Views of Responsible Officials The Organization will implement the following peer review process: ? A peer review is required to determine the appropriate sliding fee calculation was made based on family size and income of the applicant. ? A reference and training guide will be created by the Organization for front desk staff and enrollment specialists to utilize by September 30, 2023. ? Each sliding fee application will be reviewed by a peer and signed off by both the submitter and the peer reviewer. A verification checklist will be utilized to ensure the sliding fee application is accurate and complete. ? The finance department will receive a list of all new sliding fee applications from the previous month and pull a sample of twenty applications to review for accuracy and to confirm the peer review occurred. ? The Organization will implement a process where the patients will complete the sliding fee application prior to seeing the provider. The process is expected to be implemented by October 31, 2023.
2022 ? 001 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant and Community Project Funding/Congressionally Directed Spending - Construction AL Number: 93.224 & 93.527 and 93.493 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted an instance of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transaction. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) 2022 ? 001 Procurement and Suspension and Debarment (Continued) Views of Responsible Officials The Organization has updated is procurement and suspension and debarment processes to include the following procedures and internal controls: ? The Organization has implemented a process to ensure suspension and debarment checks are performed prior to entering into a transaction with new vendors. The Organization utilizes Sam.gov to perform the suspension and debarment checks. In addition to completing the suspension and debarment checks with new vendors, the accounting and compliance departments will also verify quarterly that existing vendors are not on the suspended and debarred listing. ? An Approved Vendor List will be added on the Organization?s Public Sharepoint. The approved vendor list will be added as of July 31, 2023. Before a new vendor is selected by internal management staff, they must refer to the approved vendor list to see if goods or services can be acquired from one of the approved vendors. If a new vendor must be selected, the manager must send documentation that a suspension and debarment check has occurred and a copy of the RFP (when applicable) before using the vendor for goods or services. The accounting manager will review the new vendor selection to verify that the suspension and debarment check occurred. Once this has been verified the accounts payable coordinator will be given the approval to add the new vendor to the accounting software. The accounts payable coordinator will add screen shots of the verification in the accounting software under each vendor. The accounts payable coordinator will also retain Vendor Files in Sharepoint, which include, verifications, vendor invoices, and any vendor contracts.