Finding 1130417 (2024-003)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-04-03
Audit: 352630
Organization: Desert Aids Project, Inc. (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, leading to discrepancies in the UDS Report data.
  • Impacted Requirements: Key reporting criteria for patient characteristics and clinic visits were not met, with significant differences between reported and actual figures.
  • Recommended Follow-Up: Enhance internal controls to ensure accurate documentation and review of UDS reports before submission, retaining evidence of these reviews.

Finding Text

Department of Health and Human Services Federal Financial Assistance Listing #93.224 and #93.527 Community Health Center Cluster Reporting Material Weakness in Internal Control Over Compliance Criteria Health Center Program awardees and look-alies are required to report a core set of information, including data on patient characteristics, services provided, clinical processes and health outcomes, patients’ use of services, staffing, costs, and revenues as a part of a standardized reporting system known as the Universal Data System (UDS). There is very specific criteria on how the UDS is to be completed contained in the UDS Manual published by the Health Resources and Services Administration. The information needs to be reported annually on a calendar year basis regardless of a grantees’ fiscal year-end. Condition Certain tables within the UDS Report did not reconcile to the information contained in the Organization’s records. The tables that did not reconcile to the supporting information included Table 4, Selected Patient Characteristics, and Table 5, Staffing and Utilization. Table 4 reports the total number of patients. The number of patients reported in the UDS Report was 74,680 while the number of patients noted in the supporting documentation was 73,021. Table 5 reports the number of clinic visits by both physicians and by Nurse Practitioners (NP), Physician Assistants (PA), and Certified Nurse Midwives (CNM). The number of clinic visits by physicians reported in the UDS Report was 102,677 (clinic and virtual) while the number of clinic visits by physicians noted in the supporting documentation was 115,177 (clinic and virtual). The number of clinic visits by NPs, PAs, and CNMs reported in the UDS Report was 62,915 (clinic and virtual) while the number of clinic visits by NPs, PAs and CNMs noted in the supporting documentation was 82,621 (clinic and virtual). Cause The Organization acquired Borrego Health on July 31, 2023. Borrego Health used a different medical record system than the Organization through late May 2024. This resulted in the UDS Report for the period ended December 31, 2023 needing to be prepared using two different databases for information. In addition, management did not retain the supporting detail used to prepare the UDS Report. When the supporting detail was recreated during the audit, differences were identified between the supporting detail and the UDS Report that was filed. Also, the review process of the UDS report does not appear to have been functioning properly. Effect The lack of internal control policies to require retention of supporting documentation as well as a lack of evidence of a review outside of the person preparing the report increases the risk that employees may not be able to detect and correct errors and issues in a timely manner. The Organization submitted a UDS Report that did not have supporting information and the information that was recreated does not reconcile to the amount shown in the UDS Report filed. Questioned Costs None reported. Context Seven key line items on the UDS Report are required to be reconciled to supporting documentation: 1. The total number of patients 2. Total Physician Clinic and Virtual Visits 3. Total NP, PA, and CNM Clinic and Virtual Visits 4. Total accrued costs before donations and after allocation of overhead 5. Total accrued medical staff and other medical costs after allocation of overhead excluding lab and x-ray costs 6. Total BPHC Health Center Program grants drawn down for the period from January 1 through December 31 of the calendar measurement year 7. Total accrued BPHC COVID-19 Supplemental grants drawn down for the period from January 1 through December 31 of the calendar measurement year. Two of the key line items (#1 and #2 above) did not agree to the supporting documentation. Repeat Finding From Prior Year No Recommendation We recommend that the Organization enhance internal control policies to ensure all amounts reported and submitted to the federal agency are adequately documented and supported. We also recommend that the Organization enhance internal control policies to ensure that all required reports are properly reviewed prior to submission and that all key line items are necessary, correct, meet the requirements of the federal program, and are properly reported in the reports required to be submitted to the federal agency. We also recommend that there is evidence retained of this review. Views of Responsible Officials Management agrees with the finding and has immediately implemented new procedures to memorialize the data used to compile and report the UDS report. This included adding all new acquired clinics to the Organization’s Electronic Health Record System.

Categories

Allowable Costs / Cost Principles Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 553974 2024-002
    Material Weakness
  • 553975 2024-003
    Material Weakness
  • 553976 2024-003
    Material Weakness
  • 553977 2024-004
    Material Weakness
  • 553978 2024-004
    Material Weakness
  • 1130416 2024-002
    Material Weakness
  • 1130418 2024-003
    Material Weakness
  • 1130419 2024-004
    Material Weakness
  • 1130420 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $7.07M
93.914 Hiv Emergency Relief Project Grants $2.53M
93.526 Grants for Capital Development in Health Centers $1.19M
93.527 Grants for New and Expanded Services Under the Health Center Program $938,387
14.241 Housing Opportunities for Persons with Aids $410,615
93.940 Hiv Prevention Activities Health Department Based $174,236
93.928 Special Projects of National Significance $152,721
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B $92,565
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $65,000
93.270 Viral Hepatitis Prevention and Control $52,191
93.917 Hiv Care Formula Grants $42,944
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $31,731