Finding 540583 (2024-004)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-29

AI Summary

  • Core Issue: The Organization failed to accurately prepare and submit required annual reports, leading to potential errors in the UDS and FFR.
  • Impacted Requirements: Compliance with 45 CFR 75.342 for accurate reporting and documentation of financial information.
  • Recommended Follow-Up: Revise reporting policies and procedures to ensure accuracy and maintain supporting documentation for federal grant reports.

Finding Text

Health Center Program Cluster Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award Nos. 6 H80CS26514-10-02, 3 H8FCS40655-01-01, 4 H8GCS47538-01-01, 1 H8LCS50783-01-00 Criteria or Specific Requirement – Reporting – 45 CFR 75.342 Condition – The Organization is required to prepare and submit an annual Uniform Data System (UDS) report for each calendar year and an annual Federal Financial Report (FFR) for each award and each grant year. These reports are to be prepared using accurate financial information. Questioned Costs – None Context – One report for each report type listed above was selected for testing with specific data from each report selected for testing. The sampling methodology used is not and is not intended to be statistically valid. Of the twenty-four inputs tested, sixteen exceptions were noted related to the UDS report and one exception was noted related to the annual FFR. Effect – Potential errors were made on the annual UDS and annual FFR reports. Cause – The Organization’s policies and procedures did not identify certain errors that were noted on required reports. Multiple exceptions noted on the UDS related to the Organization’s use of an estimate calculation to report patient totals in Table 4 and encounter totals in Table 5 for the 15 attributes selected for testing between the two tables. The Organization was unable to provide documentation to explain a $13,000 variance for one of the attributes selected for testing in Table 8A. The final UDS error was related to the overreporting of slide discounts and underreporting of other adjustments associated with nurse only visits coded in the practice management system. Program income was not reported on the annual FFR and therefore did not reflect the Organization’s patient service revenue from activities within scope of the health center program. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should revise policies and procedures over federal reporting to ensure reports are prepared using accurate information and supporting documentation for federal grant reports should be maintained.

Corrective Action Plan

For the 2023 Uniform Data System (UDS) report, the data was compiled using information from two different Electronic Medical Record (EMR) systems. Due to this system fragmentation, there were reporting shortfalls, and the organization relied on historical data estimates to ensure timely submission of the report. These estimates were used to comply with the UDS submission requirements, despite the data not being fully supported by direct system generated reports. For the 2024 UDS report, the organization transitioned to a single EMR system, which has significantly improved the accuracy and completeness of the data. All reported amounts for the 2024 UDS submission are now fully supported by backup data directly generated from the unified EMR system. It is important to note that the Health Resources and Services Administration (HRSA) has consistently approved the organization’s Federal Financial Report (FFR) submissions without including program income, and as such, the organization was not aware of a potential noncompliance issue related to this omission. Going forward, the organization’s Uniform Data System (UDS) reports will be consistent and based on data extracted from a single, unified Electronic Medical Record (EMR) system. This transition ensures greater accuracy and completeness in reporting, with all future UDS reports supported by direct system-generated data. Additionally, the organization will begin reporting program income on the Federal Financial Report (FFR) as part of ongoing improvements to ensure full compliance with reporting requirements. It is important to note that the current FFR report was approved by the Health Resources and Services Administration (HRSA) without program income listed, and this omission was not previously identified as a noncompliance issue. The organization is committed to maintaining transparent and accurate reporting in the future, and steps are being taken to ensure that all required data, including program income, is properly reflected in all relevant reports. This is the responsibility of the QI department and the CFO and will be complete following the next filing of the FFR and UDS.

Categories

Reporting

Other Findings in this Audit

  • 540578 2024-003
    Material Weakness
  • 540579 2024-003
    Material Weakness
  • 540580 2024-003
    Material Weakness
  • 540581 2024-003
    Material Weakness
  • 540582 2024-003
    Material Weakness
  • 540584 2024-004
    Material Weakness
  • 540585 2024-004
    Material Weakness
  • 540586 2024-004
    Material Weakness
  • 540587 2024-004
    Material Weakness
  • 540588 2024-005
    Material Weakness
  • 1117020 2024-003
    Material Weakness
  • 1117021 2024-003
    Material Weakness
  • 1117022 2024-003
    Material Weakness
  • 1117023 2024-003
    Material Weakness
  • 1117024 2024-003
    Material Weakness
  • 1117025 2024-004
    Material Weakness
  • 1117026 2024-004
    Material Weakness
  • 1117027 2024-004
    Material Weakness
  • 1117028 2024-004
    Material Weakness
  • 1117029 2024-004
    Material Weakness
  • 1117030 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.17M
93.224 Community Health Centers $1.12M
93.224 American Rescue Plan Act for Health Centers $595,028
93.527 Fy 2023 Expanding Covid-19 Vaccination $100,997
93.959 Block Grants for Prevention and Treatment of Substance Abuse $10,797
93.527 Fy 2024 Covid Bridge Access $5,850
93.527 Fy 2018 Aims Supplemental Funding $-55,112