Finding 1239165 (2025-003)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414028
Organization: Healthcore Clinic, Inc. (KS)

AI Summary

  • Core Issue: Grant funds were drawn down before actual expenditures, violating cash management rules.
  • Impacted Requirements: Noncompliance with federal cash management criteria (45 CFR 75.305).
  • Recommended Follow-Up: Improve controls to ensure federal funds are requested only for immediate cash needs and backed by actual disbursements.

Finding Text

Health Center Program Cluster – Assistance Listing Numbers 93.224 and 93.527 U.S. Department of Health and Human Services Criteria or specific requirement – Cash Management (45 CFR 75.305) Condition – Grant funds were drawn down in advance of disbursements for eligible expenditures. Cause – On January 27, 2025, the Office of Management and Budget (OMB) ordered a pause to the disbursement of federal grants to take effect the following day. Due to uncertainty around how long the pause would last, management advance drew on the Organization’s federal awards on January 28, 2025. Additionally, the Organization based drawdown requests on general ledger expenditure activity rather than actual cash disbursements. As a result, management did not consistently identify when expenditures included in drawdown requests had not yet been paid. Effect or potential effect – Federal funds were received in advance of the related cash disbursements, resulting in noncompliance with federal cash management requirements. The Organization may earn interest on federal funds held in advance of disbursement. Questioned costs – None Context – Drawdown activity for the Health Center Program awards was analyzed throughout the year. Multiple instances were identified in which cumulative drawdowns exceeded cumulative disbursements, indicating federal funds were received in advance of immediate cash needs. The largest advance draw occurred on January 28, 2025, when management requested a larger than normal drawdown in response to the federal funding pause. Based on the final expenditure population, sufficient allowable expenditures existed by year-end to support funds received; however, drawdowns were not consistently supported by actual cash disbursements at the time funds were requested. Interest earned on advance draw positions did not exceed the federal retention threshold. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should strengthen controls over the drawdown process to ensure federal funds are requested only for immediate cash needs and are supported by actual or immediately anticipated cash disbursements.

Corrective Action Plan

Management Response and Root Cause Management agrees with the finding. Five of 40 encounters tested received an incorrect sliding fee adjustment, and the approved schedule for certain dental services was not fully compliant for patients at or below 100% of the Federal Poverty Guidelines. The repeat condition resulted from incomplete alignment among the approved schedules, written policy, expanded dental services, staff workflows, income documentation, and eClinicalWorks configuration. Prior training and system optimization did not fully eliminate manual interpretation or provide sufficiently frequent monitoring across all sliding fee levels and service lines. Corrective Action Plan HealthCore Clinic will redesign and implement a single, compliant, system-supported Sliding Fee Discount Program for all services within scope. The revised process will align Board-approved policy and schedules, dental and medical workflows, income and family-size documentation, eClinicalWorks configuration, adjustment and reversal controls, staff competency, and ongoing internal audit monitoring. HealthCore Clinic will provide training on the updated program to all registration, eligibility, billing, and other affected staff. HealthCore Clinic will implement monthly internal audits using samples across tiers and service lines and investigate any errors to identify the root cause for noncompliance with the policy.

Categories

Cash Management

Other Findings in this Audit

  • 1239162 2025-002
    Material Weakness Repeat
  • 1239163 2025-002
    Material Weakness Repeat
  • 1239164 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $3.76M
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $506,838
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $35,600
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $5,932