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Marin City Health and Wellness CenterNon-Profit

EIN: 061787661

UEI: M1MCHNQN91L9

Audited by: The Pun Group, LLP

Oversight agency: 93 [Department of Health and Human Services]

View federal awards & risk assessment →

Data as of August 31, 2026

Marin City Health and Wellness Center11 audit years14 findings4 repeat
11
Audit Years
14
Total Findings
4
Repeat Findings
$2.4M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$2,416,916 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (29 days from today).

What is a management decision? →
2025-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2024-003

Fifty-one patient visit samples were selected for our internal control and compliance testing over the sliding fee discount program. Testing results noted that for one patient, the sliding fee discount applied was incorrect based on their sliding fee application. Cause: MCHWC does not have an adequate review process in place to ensure the sliding fee discounts applied are accurately determined and applied. Questioned Costs: None. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2025-003 Special Tests and Provisions (Continued) Identification as Repeat Finding, if Applicable: Yes. This finding is a repeat of prior year finding 2024-003. Recommendations: We recommend that MCHWC strengthen its policies and procedures to properly determine, input and document the patient’s eligibility in the program. MCHWC should have a secondary review on the sliding fee application forms and sliding fee discounts applied. We recommend MCHWC establish proper internal controls in reviewing that patient services are billed for patient services provided. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Management will institute an audit and review process for the sliding fee program. b) Begin to randomly select sliding fee applications with a final review and approval by the Chief Operating Officer. c) Increase training and monitoring of all staff entering sliding fee patients. d) Before the current fiscal year end, perform an audit and review of all sliding fee patients’ data, review the results with leadership and the front desk staff. e) Create a review process with third party billing company to monitor the sliding fee patients.

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Full finding narrative

Finding 2024-003 Special Tests and Provisions Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 / 93.527 Health Center Program Cluster, – Special Tests and Provisions – 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (“SFDS”) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay, family size and income for individuals and families. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Condition: Fifty-one patient visit samples were selected for our internal control and compliance testing over the sliding fee discount program. Testing results noted that for one patient, the sliding fee discount applied was incorrect based on their sliding fee application. Cause: MCHWC does not have an adequate review process in place to ensure the sliding fee discounts applied are accurately determined and applied. Questioned Costs: None. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2025-003 Special Tests and Provisions (Continued) Identification as Repeat Finding, if Applicable: Yes. This finding is a repeat of prior year finding 2024-003. Recommendations: We recommend that MCHWC strengthen its policies and procedures to properly determine, input and document the patient’s eligibility in the program. MCHWC should have a secondary review on the sliding fee application forms and sliding fee discounts applied. We recommend MCHWC establish proper internal controls in reviewing that patient services are billed for patient services provided. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Management will institute an audit and review process for the sliding fee program. b) Begin to randomly select sliding fee applications with a final review and approval by the Chief Operating Officer. c) Increase training and monitoring of all staff entering sliding fee patients. d) Before the current fiscal year end, perform an audit and review of all sliding fee patients’ data, review the results with leadership and the front desk staff. e) Create a review process with third party billing company to monitor the sliding fee patients.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Management will institute an audit and review process for the sliding fee program. b) Begin to randomly select sliding fee applications with a final review and approval by the Chief Operating Officer. c) Increase training and monitoring of all staff entering sliding fee patients. d) Before the current fiscal year end, perform an audit and review of all sliding fee patients’ data, review the results with leadership and the front desk staff. e) Create a review process with third party billing company to monitor the sliding fee patients.

Prior Finding References

2024-003

About Special Tests and Provisions →
2025-004
Cost Allowability
SIGNIFICANT DEFICIENCY

During testing of non-payroll expenditures, we noted that 2 out of 13 disbursement samples selected for testing did not contain documented evidence of required review and approval. Specifically, the check batch listings for the selected items were missing the approval signature from the CEO and the reviewer signature from the Controller. Cause: Controls related to the review and approval of disbursements were not consistently performed or documented, indicating a breakdown in the implementation or monitoring of established internal control procedures. Questioned Costs: None. Effect or Potential Effect: Failure to ensure proper review and approval of disbursements increases the risk that unallowable, inaccurate, or unauthorized costs may be charged to federal programs, which could result in noncompliance with federal cost principles and potential questioned costs. Identification as Repeat Finding, if Applicable: Not applicable. Recommendation: Management should strengthen controls over the disbursement process by ensuring that all check batch listings are reviewed and approved in accordance with established policies prior to payment, and that evidence of such review is consistently documented. Management may also consider implementing periodic supervisory monitoring procedures to verify compliance with approval requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2025-004 – Allowable Costs/Cost Principles – Internal Control over Non-Payroll Expenditures (Continued) View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Effective January 1, 2026 all purchase orders and payments are approved in the Sage system. b) Update our policies and procedure manual to ensure proper leadership is identified as approvers and provide mitigating approval based on whom is the signers of checks. c) Ensure all payment with federal funds are identified in the accounting system by utilizing a funding source. d) Implement a documented review and approval process for all payments.

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Full finding narrative

Finding 2025-004 – Allowable Costs/Cost Principles – Internal Control over Non-Payroll Expenditures Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.527 Health Center Program Cluster – Allowable Costs/Cost Principles costs charged to federal funds under the Health Center Program award funds must comply with the cost principles of 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of federal funding. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2025-004 – Allowable Costs/Cost Principles – Internal Control over Non-Payroll Expenditures (Continued) Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Condition: During testing of non-payroll expenditures, we noted that 2 out of 13 disbursement samples selected for testing did not contain documented evidence of required review and approval. Specifically, the check batch listings for the selected items were missing the approval signature from the CEO and the reviewer signature from the Controller. Cause: Controls related to the review and approval of disbursements were not consistently performed or documented, indicating a breakdown in the implementation or monitoring of established internal control procedures. Questioned Costs: None. Effect or Potential Effect: Failure to ensure proper review and approval of disbursements increases the risk that unallowable, inaccurate, or unauthorized costs may be charged to federal programs, which could result in noncompliance with federal cost principles and potential questioned costs. Identification as Repeat Finding, if Applicable: Not applicable. Recommendation: Management should strengthen controls over the disbursement process by ensuring that all check batch listings are reviewed and approved in accordance with established policies prior to payment, and that evidence of such review is consistently documented. Management may also consider implementing periodic supervisory monitoring procedures to verify compliance with approval requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2025-004 – Allowable Costs/Cost Principles – Internal Control over Non-Payroll Expenditures (Continued) View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Effective January 1, 2026 all purchase orders and payments are approved in the Sage system. b) Update our policies and procedure manual to ensure proper leadership is identified as approvers and provide mitigating approval based on whom is the signers of checks. c) Ensure all payment with federal funds are identified in the accounting system by utilizing a funding source. d) Implement a documented review and approval process for all payments.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Effective January 1, 2026 all purchase orders and payments are approved in the Sage system. b) Update our policies and procedure manual to ensure proper leadership is identified as approvers and provide mitigating approval based on whom is the signers of checks. c) Ensure all payment with federal funds are identified in the accounting system by utilizing a funding source. d) Implement a documented review and approval process for all payments.

About Allowable Costs / Cost Principles →

FY 2024-06-30

$2,992,821 federal awards expended

FAC accepted this audit on May 15, 2025 — management decision was due November 15, 2025.

2024-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

Finding 2024-003 Special Tests and Provisions Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster, – Special Tests and Provisions – 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (“SFDS”) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay, family size and income for individuals and families. Conditions: Fifty-one patient visit samples were selected for our internal control and compliance testing over the sliding fee discount program. Testing results noted that following: • For 2 patients, the sliding fee discount applied was incorrect based on their sliding fee application. • For 1 patient, they were never billed for services provided. Questioned Costs: None. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2024-003 Special Tests and Provisions (Continued) Cause: MCHWC does not have an adequate review process in place to ensure the sliding fee discounts applied are accurately determined and applied. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC strengthen its policies and procedures to properly determine, input and document the patient’s eligibility in the program. MCHWC should have a secondary review on the sliding fee application forms and sliding fee discounts applied. We recommend MCHWC establish proper internal controls in reviewing that patient services are billed for patient services provided. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Sliding fee patients will be scheduled with an enrollment counselor to review options, including sliding fee. b) Sliding fee applications will be reviewed and recommended by the respective clinic manager. c) Sliding fee applications will go through a final approval by the Chief Operations Officer. d) Due to staff limitations, the revenue cycle (billing) team will sample applications through the year.

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Full finding narrative

Finding 2024-003 Special Tests and Provisions Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster, – Special Tests and Provisions – 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (“SFDS”) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay, family size and income for individuals and families. Conditions: Fifty-one patient visit samples were selected for our internal control and compliance testing over the sliding fee discount program. Testing results noted that following: • For 2 patients, the sliding fee discount applied was incorrect based on their sliding fee application. • For 1 patient, they were never billed for services provided. Questioned Costs: None. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2024-003 Special Tests and Provisions (Continued) Cause: MCHWC does not have an adequate review process in place to ensure the sliding fee discounts applied are accurately determined and applied. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC strengthen its policies and procedures to properly determine, input and document the patient’s eligibility in the program. MCHWC should have a secondary review on the sliding fee application forms and sliding fee discounts applied. We recommend MCHWC establish proper internal controls in reviewing that patient services are billed for patient services provided. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Sliding fee patients will be scheduled with an enrollment counselor to review options, including sliding fee. b) Sliding fee applications will be reviewed and recommended by the respective clinic manager. c) Sliding fee applications will go through a final approval by the Chief Operations Officer. d) Due to staff limitations, the revenue cycle (billing) team will sample applications through the year.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Sliding fee patients will be scheduled with an enrollment counselor to review options, including sliding fee. b) Sliding fee applications will be reviewed and recommended by the respective clinic manager. c) Sliding fee applications will go through a final approval by the Chief Operations Officer. d) Due to staff limitations, the revenue cycle (billing) team will sample applications through the year.

About Special Tests and Provisions →
2024-004
Cost Allowability
SIGNIFICANT DEFICIENCY

Finding 2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster – Allowance Costs/Cost Principles – Payroll, costs charged to federal funds under Health Center Program award funds must comply with the cost principles of 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of federal funding. Conditions: For five out of eight employees selected for testing covering five different payroll pay dates, MCHWC was not able to provide a pay rate change form approved by a personnel in the Human Resources department to support the employees pay rate. Questioned Costs: None. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The lack of internal control over approving pay rate changes charged as payroll expenses to related grants resulted in the inability to test the relative compliance requirements under the grant provision. Cause: MCHWC does not have an adequate process in place to ensure that pay rate changes are properly approved by a personnel in the Human Resources department. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures (Continued) Identification as Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that MCHWC establish proper internal controls to ensure that pay rate changes are approved by a personnel in the human resources department. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Senior Human Resource Staff will prepare Personnel Action Forms. b) Director of Human Resources will review and recommend. c) Payroll Manager will approve.

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Full finding narrative

Finding 2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster – Allowance Costs/Cost Principles – Payroll, costs charged to federal funds under Health Center Program award funds must comply with the cost principles of 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of federal funding. Conditions: For five out of eight employees selected for testing covering five different payroll pay dates, MCHWC was not able to provide a pay rate change form approved by a personnel in the Human Resources department to support the employees pay rate. Questioned Costs: None. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The lack of internal control over approving pay rate changes charged as payroll expenses to related grants resulted in the inability to test the relative compliance requirements under the grant provision. Cause: MCHWC does not have an adequate process in place to ensure that pay rate changes are properly approved by a personnel in the Human Resources department. Section III – Federal Awards Findings and Questioned Costs (Continued) A. Current Year Findings and Questioned Costs – Major Federal Award Program Audit (Continued) Finding 2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures (Continued) Identification as Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that MCHWC establish proper internal controls to ensure that pay rate changes are approved by a personnel in the human resources department. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Senior Human Resource Staff will prepare Personnel Action Forms. b) Director of Human Resources will review and recommend. c) Payroll Manager will approve.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution and the following steps will be implemented: a) Senior Human Resource Staff will prepare Personnel Action Forms. b) Director of Human Resources will review and recommend. c) Payroll Manager will approve.

About Allowable Costs / Cost Principles →

FY 2023-06-30

$2,710,676 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 22, 2024 — management decision was due April 22, 2025.

FY 2022-06-30

$3,039,418 federal awards expended

FAC accepted this audit on January 17, 2024 — management decision was due July 17, 2024.

2022-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

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2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

About Reporting →
2022-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

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Full finding narrative

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

About Reporting →

FY 2022-06-30

$4,039,418 federal awards expended

FAC accepted this audit on October 22, 2024 — management decision was due April 22, 2025.

2022-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

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Full finding narrative

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

About Reporting →
2022-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

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2022-002 Reporting – Internal Control and Compliance over Reporting Information on Federal Program: Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to the Federal Financial Report (“FFR”) instructions for this federal program, recipient must submit an annual FFR through the Payment Management System reflecting cumulative reporting withing the project period of the document number. An annual FFR is due based on the budget period end date as follows: Budget period ends August-October: due January 30 Budget period ends November-January: due April 30 Budget period ends February-April: due July 30 Budget period ends May-July: due October 30 A final FFR shall be submitted at the completion of the award agreement. Condition and Context: During our audit, we noted an annual FFR due by October 30th, 2022 , was submitted on October 31st, 2022. Questioned Costs: None. Effect: The delay in filing the FFR resulted in MCHWC being non-compliant with reporting requirements. Cause: MCHWC did not have sufficient monitoring controls over reporting requirements. Identification as Repeat Finding, if Applicable: Not applicable. Recommendations: We recommend that MCHWC establish policies and procedures in specifying the deadlines for all required reporting and establish monitoring procedures in submitting required reports timely. View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

Corrective Action Plan

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Processes have been put in place to ensure the future timeliness of all required reports for Federal reporting compliance. Measures have been taken for immediate resolution, including: 1. Email alerts of upcoming due dates of all federal reporting requirements. 2. Designated tasks and due dates included in project plans that are reviewed weekly with the finance and accounting team. 3. Calendar of federal reporting requirements and due dates will be developed and distributed to leadership team, including Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Controller, Compliance Director, and Grant Management Leadership.

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FY 2021-06-30

$2,735,789 federal awards expended

FAC accepted this audit on November 2, 2022 — management decision was due May 2, 2023.

2021-003
Cost Allowability
SIGNIFICANT DEFICIENCY

For a sample grant expenditure selected for testing, the allocation of this expense was improperly recorded as a cost charged to a grant that was fully exhausted. Questioned Costs: No questioned costs. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process surrounding tracking, allocating and recording costs charged to the program may result in MCHWC not being in compliance with grant requirements.

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2021 ? 003 Allowable Costs/Cost Principles ? Internal Control over Non-Payroll Expenditures Information on Federal Program: Assistance Listing Number: 93.224 Title: Health Center Program Cluster (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency: Department of Health and Human Services Pass-Through Entity: Not Applicable Federal Award Number and Award Year: H80CS22689; 2021 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster, - Allowable Costs/Cost Principles costs charged to federal funds under the HCP award funds must comply with the cost principles at 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of federal funding. Condition: For a sample grant expenditure selected for testing, the allocation of this expense was improperly recorded as a cost charged to a grant that was fully exhausted. Questioned Costs: No questioned costs. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process surrounding tracking, allocating and recording costs charged to the program may result in MCHWC not being in compliance with grant requirements.

Corrective Action Plan

2021-003 Allowable Costs/Cost Principles ? Internal Control over Non-payroll Expenditures View of Responsible Official and Planned Corrective Actions: MCHWC understands and agrees with the findings. Fiscal year 2021 experienced challenges with changes to the contracted CFO. A new contracted CFO company was hired in July 2021 and processes have been put in place to account for the correct allocation of expenses to grants. This includes: 1. All budget material, supporting documents, Notice of Awards, and applicable documentation related to the fiscal management of Grant funding programs will be maintained and accessible to all finance and accounting staff 2. Procurement processes and policies will be updated to ensure all procurement of goods and services associated with grant funding will be correctly applied in the accounting system and reviewed and approved by the Controller and/or CFO Responsible Person: Harold Wallace, CEO Expected Implementation Date: 11/30/2022

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2021-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2020-002

2021 ? 004 Special Tests and Provisions Information on Federal Program: Assistance Listing Number: 93.224 Title: Health Center Program Cluster (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency: Department of Health and Human Services Pass-Through Entity: Not Applicable Federal Award Number and Award Year: H80CS22689; 2021 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster, - Special Tests and Provision ? 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (?SFDS?) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay, family size and income for individuals and families. Pursuant to Code of Federal Regulations Title 42 Section 51c.304, for grant-receiving community health centers, the governing board should be composed of a majority of individuals who are or will be served by the center. Conditions: Sliding Fee Discount Program Sixty patient visit samples were selected for our internal control and compliance testing over the sliding fee discounts program. Testing results noted the following: ? For 2 patients, sliding fee applications were unavailable. ? For 7 patients, the sliding fee discount applied was incorrect based on their sliding fee application. ? For 1 patient, an entry error was made in the system resulting in an incorrect sliding fee discount applied. ? For 1 patient visit, payment due has been at least over two years outstanding and for another 4 patient visits, payment due has been at least over a year outstanding. Governing Board Patient Majority Requirement MCHWC?s governing body, consisting of 11 members, included only 4 patient members. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. MCHWC maintains a governing body to oversee its programs, but it was unable to demonstrate compliance with the governing body patient majority requirement. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. By not ensuring its governing body was composed of a majority of patients, MCHWC limited the ability of patients receiving services to oversee the program.

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2021 ? 004 Special Tests and Provisions Information on Federal Program: Assistance Listing Number: 93.224 Title: Health Center Program Cluster (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency: Department of Health and Human Services Pass-Through Entity: Not Applicable Federal Award Number and Award Year: H80CS22689; 2021 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB Compliance Requirement for Assistance Listing 93.224 Health Center Program Cluster, - Special Tests and Provision ? 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (?SFDS?) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay, family size and income for individuals and families. Pursuant to Code of Federal Regulations Title 42 Section 51c.304, for grant-receiving community health centers, the governing board should be composed of a majority of individuals who are or will be served by the center. Conditions: Sliding Fee Discount Program Sixty patient visit samples were selected for our internal control and compliance testing over the sliding fee discounts program. Testing results noted the following: ? For 2 patients, sliding fee applications were unavailable. ? For 7 patients, the sliding fee discount applied was incorrect based on their sliding fee application. ? For 1 patient, an entry error was made in the system resulting in an incorrect sliding fee discount applied. ? For 1 patient visit, payment due has been at least over two years outstanding and for another 4 patient visits, payment due has been at least over a year outstanding. Governing Board Patient Majority Requirement MCHWC?s governing body, consisting of 11 members, included only 4 patient members. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. MCHWC maintains a governing body to oversee its programs, but it was unable to demonstrate compliance with the governing body patient majority requirement. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. By not ensuring its governing body was composed of a majority of patients, MCHWC limited the ability of patients receiving services to oversee the program.

Corrective Action Plan

2021-004 Special Tests and Provisions - Internal Control and Compliance over Sliding Fee Discounts Program View of Responsible Official and Planned Corrective Actions: With the onset of the pandemic in 2020, MCHWC experienced a high level of turnover, including staff in key operational positions. In 2021 MCHWC focused on recruiting and hiring of key staff and ensure training processes, however, turnover persisted through 2021. In 2022, key positions, including a Director of HR and Chief Operating Officer have been added to the team to ensure policies and processes related to the Sliding Fee Discount Program are updated and working effectively. This will include: 1. Peer reviews of sliding fee application processing 2. Internal audits of the sliding fee program to ensure documents were received and scanned and appropriate discount schedules were applied and adjusting appropriately in the system 3. Updates to collection policies and procedures to ensure patient balances are collected upon in a timely manner Responsible Person: Kim Walker, Chief Operating Officer Expected Implementation Date: 11/30/2022

Prior Finding References

2020-002

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FY 2020-06-30

$2,158,229 federal awards expended

FAC accepted this audit on June 14, 2021 — management decision was due December 14, 2021.

2020-002
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-002

Sliding Fee Discount During testing of MCHWC?s sliding fee discount program, seven of 60 sampled claims tested included sliding fee discounts that were not correctly applied or supported, likely resulting in instances of patient underpayment and/or overpayment. Governing Board Patient Majority Requirement MCHWC?s governing body, consisting of 11 members, included only four patient members. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. MCHWC maintains a governing body to oversee its programs, but it was unable to demonstrate compliance with the governing body patient majority requirement. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. By not ensuring its governing body was composed of a majority of patients, MCHWC limited the ability of patients receiving services to oversee the program.

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2020 ? 002 Special Tests and Provisions Information on Federal Program: Catalog of Federal Domestic Assistance ("CFDA") Number: 93.224 CFDA Title: Health Center Program (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency Department of Health and Human Services Pass-Through Entity: Not Applicable Federal Award Number and Award Year: H80CS22689; 2020 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB August 2020 Compliance Requirement for CFDA 93.224 Health Center Program Cluster, - Special Tests and Provision ? 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (?SFDS?) so that the amounts owed for the health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay, family size and income for individuals and families. Pursuant to Code of Federal Regulations Title 42 Section 51c.304, for grant-receiving community health centers, the governing board should be composed of a majority of individuals who are or will be served by the center. Condition: Sliding Fee Discount During testing of MCHWC?s sliding fee discount program, seven of 60 sampled claims tested included sliding fee discounts that were not correctly applied or supported, likely resulting in instances of patient underpayment and/or overpayment. Governing Board Patient Majority Requirement MCHWC?s governing body, consisting of 11 members, included only four patient members. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. MCHWC maintains a governing body to oversee its programs, but it was unable to demonstrate compliance with the governing body patient majority requirement. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements. By not ensuring its governing body was composed of a majority of patients, MCHWC limited the ability of patients receiving services to oversee the program.

Corrective Action Plan

2020 ? 002 Special Tests and Provisions Responsible Officials and Planned Corrective Actions: During Fiscal Year End June 30, 2020, MCHWC experienced a sudden reduction in staffing affecting the entire organization because of COVID and also the loss of a key operational position. MCHWC began in April 2021 to reevaluate its front desk and revenue cycle staff to begin a training process and develop a protocol for adherence to ensuring the sliding fee discount program is properly functioning and documented appropriately in the patient?s files. This will entail a review and approval process of sliding fee patients. This will fall under the responsibility of the Director of Operations. Another avenue we will pursue will be to perform an audit and review all prior sliding fee-scale patients to ensure issues are identified and corrected before Fiscal Year End June 30, 2021. MCHWC understand and agrees with the findings. During Fiscal Year End 2020, as noted above, the clinic was experiencing staffing challenges including the loss of the Chief Executive Officer. A new Chief Executive Officer began in October 2021. It will be the Chief Executive Officer?s responsibility to ensure a review is periodically performed at any change in patient board members to ensure compliance is maintained. This will be completed by June 30, 2021. Responsible person: Harold Wallace, CEO Expected implementation date: June 30, 2021

Prior Finding References

2019-002

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2020-003
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-003QUESTIONED COSTS

Forty samples were selected for internal control and compliance testing over payroll expenditures. MCHWC was unable to provide documentation of its personnel?s established pay rates for all the samples. Questioned Costs: $2,104,822 Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The lack of appropriate internal control over employee payrate change file resulted inability of testing the relative compliance requirements under the grant provision.

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2020 ? 003 Allowable Costs/Cost Principles ? Internal Control Over Payroll Information on Federal Program: Catalog of Federal Domestic Assistance ("CFDA") Number: 93.224 CFDA Title: Health Center Program (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency Department of Health and Human Services Pass-Through Entity: Not Applicable Federal Award Number and Award Year: H80CS22689; 2020 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB August 2020 Compliance Requirement for CFDA 93.224 Health Center Program Cluster, - Allowable Costs/Cost Principles ? Payroll, health centers? costs charged to Federal funds under the HCP award funds must comply with the cost principles at 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of Federal funding. Condition: Forty samples were selected for internal control and compliance testing over payroll expenditures. MCHWC was unable to provide documentation of its personnel?s established pay rates for all the samples. Questioned Costs: $2,104,822 Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The lack of appropriate internal control over employee payrate change file resulted inability of testing the relative compliance requirements under the grant provision.

Corrective Action Plan

2020 ? 003 Allowable Costs/Cost Principles ? Internal Control Over Payroll View of Responsible Officials and Planned Corrective Actions: As of April 2021, MCHWC has staffed the human resources and oversight of payroll functions with a Director of Human Resources. As noted above in Finding 2020-01, excessive tasks were assigned to the lone staff residing in the accounting/finance department. The Director of Human Resources has taken responsibility for the creation of proper paperwork with the appropriate approvals. This corrective action will be completed by June 30, 2021. MCHWC understands and agrees with this finding for FYE 2020. Responsible person: Harold Wallace, CEO Expected implementation date: June 30, 2021

Prior Finding References

2019-003

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FY 2019-06-30

LOW-RISK AUDITEE$2,270,187 federal awards expended

FAC accepted this audit on July 22, 2020 — management decision was due January 22, 2021.

2019-002
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

During our testing of MCHWC?s sliding fee discount program, 4 out of 40 sliding fees tested did not have patient?s application form. Furthermore, during our testing, we noted there were 5 out of 40 separate instances where the sliding fee discounts were not correctly applied: 1.We noted that MCHWC applied 60% sliding discount into the system which should be discounted at $89.4. The patient should have been charged 40% of total charges, however, it was incorrectly calculated and as a result, this patient received $2.4 more in sliding fee discount. 2.We noted that one patient was under the sliding fee schedule, during the sliding fee testing, we noted that the patient?s application was inaccurate, and the proof of income shows he does not qualify for discount due to the income above the threshold. Per MCHWC?s e-CW report, MCHWC?s billing team had removed the adjustment, and the patient was charge for the visit. 3.A patient received dental services from MCHWC, the patient should be charged under the Scale B with nominal fee of $75. However, the patient was charged 50% of the total visit, which was over charged by $945. 4.We noted that a patient was entered into system with sliding fee scale B for dental service. The patient should pay the nominal fee of $50 for the visit, however, the patient was charged for $125. We noted that the patient only paid $50, and the reminding $75 was remained as receivable. 5.We noted a patient was entered into system with sliding fee scale B for behavioral service. The patient should be paid nominal fee of $10 for the visit, however, the billing system charged at $20 for the visit, we noted that the patient only paid $10, and the remaining $10 was remained as receivable. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements.

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2019 ? 002 Special Tests and Provisions ? Internal Control Over Sliding Fee Discounts Program Information on Federal Program: Catalog of Federal Domestic Assistance ("CFDA") Number:93.224 CFDA Title:Health Center Program (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency:Department of Health and Human Services Pass-Through Entity:Not Applicable Federal Award Number and Award Year:H80CS22689; 2019 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB August 2019 Compliance Requirement for CFDA 93.224 Health Center Program Cluster, - Special Tests and Provision ? 1. Sliding Fee Discounts, health centers must prepare and apply a sliding fee discount schedule (?SFDS?) so that the amounts owed for the health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay, family size and income for individuals and families. Condition: During our testing of MCHWC?s sliding fee discount program, 4 out of 40 sliding fees tested did not have patient?s application form. Furthermore, during our testing, we noted there were 5 out of 40 separate instances where the sliding fee discounts were not correctly applied: 1.We noted that MCHWC applied 60% sliding discount into the system which should be discounted at $89.4. The patient should have been charged 40% of total charges, however, it was incorrectly calculated and as a result, this patient received $2.4 more in sliding fee discount. 2.We noted that one patient was under the sliding fee schedule, during the sliding fee testing, we noted that the patient?s application was inaccurate, and the proof of income shows he does not qualify for discount due to the income above the threshold. Per MCHWC?s e-CW report, MCHWC?s billing team had removed the adjustment, and the patient was charge for the visit. 3.A patient received dental services from MCHWC, the patient should be charged under the Scale B with nominal fee of $75. However, the patient was charged 50% of the total visit, which was over charged by $945. 4.We noted that a patient was entered into system with sliding fee scale B for dental service. The patient should pay the nominal fee of $50 for the visit, however, the patient was charged for $125. We noted that the patient only paid $50, and the reminding $75 was remained as receivable. 5.We noted a patient was entered into system with sliding fee scale B for behavioral service. The patient should be paid nominal fee of $10 for the visit, however, the billing system charged at $20 for the visit, we noted that the patient only paid $10, and the remaining $10 was remained as receivable. Questioned Costs: Not determinable. Context: Sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The absence of an appropriate review process may result in MCHWC not being in compliance with grant requirements.

Corrective Action Plan

2019 ? 002 Special Tests and Provisions ? Internal Control Over Sliding Fee Discounts Program Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with this finding. MCHWC clearly needs to strengthen the training process and oversight of the front desk staff to ensure better adherence to the Sliding Fee Discount Program policies. MCHWC also needs to have another staff person review each and every application to ensure that the patient qualifies for discount and that the calculations have been performed correctly. This will be done within the next two months from June, 2020. Responsible person: Judith P. Waterman, Contracted CFO Expected implementation date: August 1, 2020

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2019-003
Cost Allowability
MODIFIED OPINIONSIGNIFICANT DEFICIENCY

Forty samples were selected for our internal control and compliance testing over payroll expenditure testing. We noted that one instance where an employee?s payrate changed form were not able to located. Questioned Costs: No questioned cost noted. Context: Statistical sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The deficiency in internal control to keep employee?s payrate changed file may result in MCHWC not being in compliance with grant requirements.

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2019 ? 003 Allowable Costs/Cost Principles ? Internal Control Over Payroll Information on Federal Program: Catalog of Federal Domestic Assistance ("CFDA") Number:93.224 CFDA Title:Health Center Program (Community Health Centers, Migrant Health Center, Health Care for the Homeless, and Public Housing Primary Care) Federal Agency:Department of Health and Human Services Pass-Through Entity:Not Applicable Federal Award Number and Award Year:H80CS22689; 2019 Criteria or Specific Requirement (Including Statutory, Regulator, or Other Citation): Pursuant to OMB August 2019 Compliance Requirement for CFDA 93.224 Health Center Program Cluster, - Allowable Costs/Cost Principles ? Payroll, health centers? costs charged to Federal funds under the HCP award funds must comply with the cost principles at 45 CFR part 75, subpart E, and any other requirements or restrictions on the use of Federal funding. Condition: Forty samples were selected for our internal control and compliance testing over payroll expenditure testing. We noted that one instance where an employee?s payrate changed form were not able to located. Questioned Costs: No questioned cost noted. Context: Statistical sampling was performed to draw sample selections. See condition above for context of the finding. Effect or Potential Effect: The deficiency in internal control to keep employee?s payrate changed file may result in MCHWC not being in compliance with grant requirements.

Corrective Action Plan

2019 ? 003 Allowable Costs/Cost Principles ? Internal Control Over Payroll Responsible Officials and Planned Corrective Actions: MCHWC understands and accepts this finding. MCHWC?s corrective action will be to have the newly-hire internal HR Manager manage the employee personnel files, including the Status Change Request forms. This will be implemented within the next month from June, 2020. Responsible person: Judith P. Waterman, Contracted CFO Expected implementation date: July 1, 2020

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FY 2018-06-30

LOW-RISK AUDITEE$2,988,700 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 21, 2019 — management decision was due August 21, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$1,987,722 federal awards expended

FAC accepted this audit on March 21, 2018 — management decision was due September 21, 2018.

2017-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

LOW-RISK AUDITEE$1,434,390 federal awards expended

FAC accepted this audit on February 1, 2017 — management decision was due August 1, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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