Finding 4262 (2022-004)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-12-13

Audit: 6569

Organization: Asian and Pacific Islander Wellness Center, Inc. D/b/a San Francisco Community Health Center (CA)

Auditor: Chw LLP

AI Summary

Core Issue: The Center drew down funds before actually spending them on program costs.
Impacted Requirements: This practice violates the requirement to minimize the time between fund transfer and disbursement.
Recommended Follow-Up: Improve tracking of grant expenditures and only draw down funds at month-end based on actual spending.

Finding Text

2022-004 Cash Management Compliance ALN: 93.834 Program: National Capacity Building Programs Agency: US Department of Health and Human Services Compliance Requirement: (C) Cash Management Repeat Finding: No Criteria: Non-Federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-Federal entity for program costs. Finding/ Condition: The Center made drawdowns of funds prior to incurring program expenditures. Questioned Cost: None. Effect: Early drawdowns create potential liabilities to the federal government and can affect future funding opportunities. Cause: Grant expenditures were not adequately tracked to be able to determine the proper amounts to drawdown. Recommendation: We recommend the Center improve the tracking of grant expenditures for all programs and then drawdown funds at month end based on the expenditures for the month. Views of Responsible Officials and Corrective Action Plan: The Center agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 36.

Corrective Action Plan

2022-003 Compliance Over Reporting Name of Contact Person: Chief Financial Officer: Amber Curley Corrective Action: The Center agrees with this finding which is directly related to the transitions in financial leadership and the need for a more robust finance team. The Center’s full-time permanent CFO was hired in January 2022 who then immediately increased the team by two new members (1.0 FTE Controller hired in July 2022 and 1.0 FTE Staff Accountant hired in January 2023) and overhauled the Center’s financial policies and procedures manual. With the five-member finance team currently in place, we are on track to complete our FY2022-23 audit process by December 31, 2023. It is also relevant to note that San Francisco community health clinics migrated en masse to OCHIN Epic in 2022 with the overarching goal of our safety net hospitals and all community clinics being on the same EHR system to strengthen patient health outcomes for our city. The Center’s go-live date for this was June 2022 and required extensive time from all executive management, with our newly hired CFO being a key leader in this migration. This one-time, significant event had a direct impact on our ability to complete our audit in a timely manner. Proposed Completion Date: June 30, 2023

Other Findings in this Audit

4260 2022-002

Significant Deficiency Repeat
4261 2022-003

Significant Deficiency
580702 2022-002

Significant Deficiency Repeat
580703 2022-003

Significant Deficiency
580704 2022-004

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.834	Capacity Building Assistance (cba) for High-Impact Hiv Prevention	$680,646
93.914	Hiv Emergency Relief Project Grants	$358,530
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$214,305
93.918	Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease	$140,666
93.224	Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)	$2,366