Cambridge Public Health Commission / Cambridge Health AllianceLocal Government

2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services Passthrough Agency: The Commonwealth of Massachusetts Department of Public Health Program Name: Family Planning – Services Project Grant (FPSPG) Award Name: Family Planning Services Award Year: 2024 Award Number: INTF3323MM3230133136 Assistance Listing Number: 93.217 Criteria The Department of Health and Human Services policy manual requires permissible cost transfers to be made promptly after the error occurs but no later than 90 days following the occurrence unless a longer period is approved in advance by the Grants Management Office. The Alliance’s Cost Transfer policy is to complete the Cost Transfer Explanation & Justification Form (“Form”) and to obtain the necessary approvals. The Form is required for cost transfers less than 90 days that are either (1) $500 or greater or (2) outside the accounting period (month). For cost transfers over 90 days, the Alliance must complete the Form including an explanation for the lateness of the transfer and obtain the approval by the Department Chairperson and the Director of Sponsored Research Administration. Condition Through our testing of the cost transfers over the Family Planning Services award, we selected three cost transfers. For each of the three selections, the entity did not complete the required Form and was not able to evidence that appropriate approval was obtained for the cost transfer. Cause For two of the samples that were processed within 90 days, the Alliance completed a hospital non-staffing reclass request form but did not complete a Cost Transfer Explanation & Justification Form as required. For the third sample relating to payroll reclasses for one individual over 90 days, no Form was completed. The individual completing the cost transfers was not aware of the Cost Transfer Explanation & Justification Form requirement. Effect The Alliance did not properly complete the Cost Transfer Explanation & Justification Form for the three samples. Although the cost transfers were deemed to be allowable, the Alliance did not retain any evidence that appropriate approvals were obtained. Questioned Costs There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation The Alliance should implement training and communication to clarify their cost transfer policy over the Form and the required approvals. Management’s Views and Corrective Action Plan Please refer to the Alliance’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.

2024 – 002 – Procurement Grantor: Department of Health and Human Services Passthrough Agency: N/A Program Name: Community Project Funding/Congressionally Directed Spending - Construction Award Name: Congressional Directives Award Year: 2024 Award Number: 6 CE1HS47194-01-10 Assistance Listing Number: 93.493 Criteria 2 CFR 200.318(i) stipulates that non-Federal entities must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition The Alliance’s Procurement policy states that bidding is required for expenditures greater than $5,000. A minimum of two bids are required for any expenditures between $5,000 and $50,000 and a minimum of three bids are required for any expenditures greater than $50,000. The policy states that any purchase transactions above $25,000 are required to be approved by the head of the department. For two of the five samples selected for testing, the Alliance received the appropriate bids, but did not retain adequate documentation to support the basis for selecting the contractor. The Alliance did not retain documentation that the cost or price analysis was performed. Cause For the two samples, the individual completing the contractor selection process did not have the appropriate understanding that the basis for selecting the contractor was required to be formally documented or that the cost or price analysis was required to be formally documented and maintained. Effect Although the procurement policy was followed regarding the bidding process, no documentation was retained for the rationale regarding the selection of the contractor. Therefore, the Alliance was not in compliance with policy. Questioned Costs None noted. Recommendation The Alliance should implement training and communication to enforce their procurement policy over the bidding process including maintaining documentation of the decision between competing bids. Management’s Views and Corrective Action Plan Please refer to the Alliance’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.

2024 – 003 – Reporting Grantor: Department of Health and Human Services Passthrough Agency: N/A Program Name: Community Project Funding/Congressionally Directed Spending - Construction Award Name: Congressional Directives Award Year: 2024 Award Number: 6 CE1HS47194-01-10 Assistance Listing Number: 93.493 Criteria 2 CFR 200.328 requires non-Federal entities to submit financial reports as required by the Federal award. Condition Per the award agreement, the Federal Financial Report for the period of September 1, 2022 to August 31, 2023 was required to be submitted before January 30, 2024. Through our testing of the reporting over the Congressional Directives award, we selected the one Federal Financial Report (“FFR”) required to be issued in FY24, which was for the period of September 1, 2022 to August 31, 2023. For the one selection tested, the Alliance did not submit the Federal Financial Report prior to the due date of January 30, 2024. The Alliance could not provide additional supporting documentation indicating there was any pre-approval or acknowledgement for submitting reports late as is required per the award agreement. Cause For the selection tested, the Alliance noted that there was a delay in setting up an authorized employee with the appropriate system access due to the internal review requirements for new users. As the delay in receiving employee’s clearance continued, another Alliance employee (an approved analyst) filed the FFR on February 5, 2024, after being requested to do so. Effect The Alliance did not submit the FFR within the appropriate period per the award agreement, within the due date of January 30, 2024. Therefore, the Alliance was not in compliance with reporting requirements. Questioned Costs None noted. Recommendation The Alliance should ensure that timely submission of reports is performed as stated within agreed-upon award agreements with Department of Health and Human Services. Management’s Views and Corrective Action Plan Please refer to the Alliance’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.

2021-001: Reporting with the Health Resources & Services Administration (HRSA) Provider Relief Fund Portal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Agency: Department of Health and Human Services (HHS) Health Resources and Services Administration (HRSA) Award Year: 1/1/2020-6/30/2021 Award Number: Not available Condition In September 2021, the Alliance?s management submitted their Period 1 Provider Relief Fund Portal submission, which included provider relief fund expenses. Subsequent to the submission, management identified a formulaic error within the tracking spreadsheet of incremental COVID-19 expenditures which was used to determine the provider relief fund expenses reported. As such, the total expenses of $57,358,152 reported into the portal were understated by $4,378,839, with certain expense types being understated or (overstated) for each quarter. The following table illustrates the impact to the provider relief expenses for each quarter within reporting Period 1. See Schedule of Findings and Questioned Costs for chart/table. Criteria Law (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) notes that Provider Relief Funds should be used to prevent, prepare for, and respond to coronavirus and COVID-19, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Cause The Alliance?s tracking and calculations of COVID-19 expenses are excel spreadsheet based. This manual tracking of expenditures led to a formulaic error within the spreadsheet, which management did not identify during their review prior to the submission of the Period 1 portal filing. Management identified this error subsequently when assessing past expenditures in preparation for requesting incremental grant funding to cover additional COVID-19 expenses incurred. Effect Provider relief fund expenses were either understated or overstated within each expense category during the reporting period 1 quarters. Questioned Costs As noted in the table above, certain categories of costs were either (overstated) or understated as a result of the spreadsheet error. In total, the costs reported were understated, but the underlying support (invoices, payroll records, etc.) were properly supported for allowability with the terms and conditions of the award and as such, there were no questioned costs. Additionally, when combined with lost revenue, the Alliance had more than sufficient costs to support the receipt of the Period 1 funds. Recommendation We recommend management design and implement an internal control around review of the HRSA reporting and perform incremental mathematical accuracy checks over the manual tracking spreadsheet of COVID-19 expenses. Additionally, management should reach out to HRSA to determine how to correct the errors noted in their Period 1 portal submission. Management's Views and Corrective Action Plan Management?s views and corrective action plan is included at the end of this report.

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