BROOKLYN PLAZA MEDICAL CENTER, INC.Non-Profit

Section III - Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) FAIN # H8000410, H8N53897, and H8L50850 for 2024 - (Material Weakness) Item 2024-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2024. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2024. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to two out of 57 patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2024. Identification as a Repeat Finding Condition is a repeat finding - see 2023-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official As part of the corrective action plan addressing the two errors identified out of the 57 patient files reviewed by the auditors, the Center has continued the initiative implemented in late September 2024. Under this initiative, the CEO designated the Compliance Officer to conduct daily audits of documentation related to the Sliding Fee Scale (SFS). These real-time audits enable prompt identification and correction of issues, with findings regularly integrated into staff training programs. While we are encouraged by the progress made, we remain committed to achieving full compliance and will continue to refine our processes and training efforts to meet that goal.

Section III - Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2023-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2023. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2023. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to three out of twenty-four patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2023. For two of these patients, there was no supporting documentation on file to support the sliding fee discount provided. Identification as a Repeat Finding Condition is a repeat finding - see 2022-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official As part of the corrective action plan for this finding, the Center hired a consulting firm in September 2023 to perform a comprehensive review of the Center's electronic medical record system to ensure that the system setup is correct and that proper reports are being generated. In addition, the consulting firm is training all front desk staff, including the director and supervisors and conducting bi-weekly audits to ensure that the staff is complying with the sliding fee scale program. Lastly, the Chief Compliance Officer will be conducting daily audits of transactions that occurred the previous business day to ensure compliance with the sliding fee program.

Section III - Federal Award Findings and Questioned Costs U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Item 2022-001 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2022. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to four out of eleven patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2022. For one of these patients, there was no supporting documentation on file to support the sliding fee discount provided. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2022. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2021-001. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that additional controls will be put in place to timely detect systems and human errors in the sliding fee discount calculation. The Center will strengthen its monthly internal audits to monitor compliance with the sliding fee discount policies and procedures. The Center has also hired a consulting firm to do a comprehensive review of the electronic medical record system and help train the front desk staff, including the director and supervisor. The consulting firm will also conduct bi-weekly audits for six months to ensure the issue is resolved.

Item 2021-001 - Special Tests and Provisions U.S Department of Health and Human Services, COVID-19 Health Center Program Cluster (CFDA 93.224/93.527) Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2021. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to four out of eleven patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2021. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2021. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2020-002. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that additional controls will be put in place to timely detect systems and human errors in the sliding fee discount calculation. The Center will strengthen its quarterly internal audits to monitor compliance with the sliding fee discount policies and procedures.

Item 2020-002 - Special Tests and Provisions U.S Department of Health and Human Services, COVID-19 Health Center Program Cluster (CFDA 93.224/93.527) Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2020. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to three out of fifteen patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2020. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2020. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2019-003. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Views of Responsible Official The Center concurs with this finding and will ensure that additional controls will be put in place to timely detect systems and human errors in the sliding fee discount calculation. The Center will strengthen its quarterly internal audits to monitor compliance with the sliding fee discount policies and procedures.

Item 2020-003 - Time and Effort Reporting and Salary Expense Allocation U.S Department of Health and Human Services, COVID-19 Health Center Program Cluster (CFDA 93.224/93.527) Criteria All program expenses, including indirect expenses, should be recognized and duly allocated to the respective programs in the general ledger. In addition, the Uniform Guidance requires that time and effort reporting should be maintained, that accounts for the total activity of employees and the programs/funding sources charged. Per the Center's policy, the reports must be approved and signed by a direct supervisory official having firsthand knowledge of the activities performed by the employee indicating that the time and effort recorded on the attestation forms reflects the employees' funding sources. Statement of Condition For the first quarter of 2020, personnel costs were not timely allocated to the appropriate program/funding source in the general ledger in accordance with the Center's policy. In addition, monthly time and effort attestation forms were not prepared for the employees who were allocated 100% to the 330 grant. Questioned Costs None Context While performing our audit, it was noted that the Center does not allocate personnel costs in a timely manner to each program/funding source in the general ledger. In addition, time and effort attestation reports were not prepared for employees who are funded 100% by the 330 grant for the first quarter in 2020 in accordance with the Center's policy. Cause Due to turnover in the financial leadership position, time and effort reporting was not being performed. In addition, proper processes and controls have not been established. Effect The Center was not in compliance with the requirement regarding timely and proper completion of time and effort reporting. Identification as a Repeat Finding Condition is a repeat finding - see 2019-004. Recommendation We recommend that the Center prepare time and effort attestations reports in accordance with the regulations of the Uniform Guidance and the Center's policy. These reports should be reviewed and signed by the direct supervisor in accordance with the Center's policy. The Center should perform quality control on the review and approval process of time and effort reporting periodically throughout the year. We also recommend that all program expenses, including indirect expenses, be recognized and duly allocated to the respective programs in the general ledger. This will ensure that the program-level profit and loss statements for any period are accurate and will provide more reliable information to users of such statements when evaluating the status of the programs. Views of Responsible Official Management and the board of directors agree. In an effort to improve the Center's time and effort attestation compliance, the Center has computerized that function through the payroll system. The system allows employees to allocate their efforts within the system as they are completing their timesheets. In addition, monthly adjustments are being made to adjust the general ledger to account for the allocation of costs to the programs.

Item 2019-003 - Special Tests and Provisions Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5), 56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review sliding fee discounts issued to patients in accordance with the Center's sliding fee scale. Statement of Condition While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2019. In addition, for some of the patients selected for testing, supporting documentation was not maintained on file to support the slide the patient was given. Questioned Costs None Context While performing our audit, we noted that the Center did not properly determine the sliding fee discount category given to four out of fifteen patients selected for testing based on the sliding fee scale in effect for the year ended December 31, 2019. In addition, the Center did not properly maintain the supporting documentation on file to support the sliding fee discount category given to an additional two patients selected for testing. Cause The condition can be attributed to human error and the lack of internal controls to review and ensure that the proper sliding fee documentation is being maintained and applied. Effect The Center did not comply with the determination of sliding fee discounts based on the federal poverty guidelines in effect for the year ended December 31, 2019. In addition, the Center may not have properly calculated the sliding fee or discount given to the patients and the discount given, if any, may not have been based on the patient's ability to pay. Identification as a Repeat Finding Condition is a repeat finding - see 2018-003. Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure proper documentation is maintained on file to support the sliding fee discounts given.

Item 2019-004 - Time and Effort Reporting and Salary Expense Allocation Criteria All program expenses, including indirect expenses should be recognized and duly allocated to the respective programs in the general ledger. In addition, the Uniform Guidance requires that time and effort reporting should be maintained, that accounts for the total activity of employees and the programs/funding sources charged. These reports should be as stipulated per their policy as stated in accordance with the Uniform Guidance. Per the Center's policy, the reports must be approved and signed by a direct supervisory official having firsthand knowledge of the activities performed by the employee indicating that the time and effort recorded on the attestation forms reflects the employees' funding sources. Statement of Condition During the year ended December 31, 2019, personnel costs and other than personnel costs were not allocated to the appropriate program/funding source in the general ledger in accordance with the Center's policy. In addition, monthly time and effort attestation forms were not prepared for the employees documenting their time and effort allocations between the various funding sources in accordance with the Center's policy. Questioned Costs None Context While performing our audit, it was noted that the Center does not allocate personnel costs to each program/funding source in the general ledger. In addition, time and effort attestation reports were not prepared for employees for the year ended December 31, 2019 in accordance with the Center's policy. Cause Due to turnover in the financial leadership position, time and effort reporting was not being performed. In addition, a new general ledger system was implemented in 2018 and the allocation of costs by program/funding source was not setup. Effect The Center was not in compliance with the requirement regarding timely and proper completion of time and effort reporting. Identification as a Repeat Finding Condition is a repeat finding - see 2018-004. Recommendation We recommend that the Center prepare time and effort attestations reports in accordance with the regulations of the Uniform Guidance and the Center's policy. These reports should be reviewed and signed by the direct supervisor in accordance with the Center's policy. The Center should perform some quality control on the review and approval process of time and effort reporting periodically throughout the year. We also recommend that all program expenses, including indirect expenses be recognized and duly allocated to the respective programs in the general ledger. This will ensure that the program-level profit and loss statements for any period are accurate and will provide more reliable information to users of such statements when evaluating the status of the programs.

Item 2019-005 - Books and Records and Audit Reporting Criteria All accounts must be reconciled and reviewed on a timely basis to ensure the financial statements are presented fairly in accordance with generally accepted accounting principles in the United States of America ("GAAP"). In addition, in accordance with the Uniform Guidance, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House, within the earlier of 30 days after the receipt of the audit report or 9 months after the end of the audit period. Due to COVID-19, a three month extension was provided which resulted in a due date of December 31, 2020. Statement of Condition There were certain accounts that were not reconciled until after year-end, which resulted in adjustments that had to be made to the general ledger and ultimately, resulted in late filing of the audit report. These accounts included: ? Cash, ? Patient services revenue and receivables, ? 340B pharmacy revenue and receivables, ? Account payable and accrued expenses and ? In kind contributions In addition, we noted that the reconciliation of the gross receivable balances by payer between general ledger and subsidiary ledgers were not reconciled. Thus, the balances were adjusted after year-end. Questioned Costs None Context The Center did not submit its annual audit on a timely basis. Cause The Center had staff turnover in the financial leadership position during the audit period. As a result, the Center's finance department was not able to perform detailed reviews of accounts and adjust the books accordingly, which delayed the filing of the audit report. Effect This condition may lead to inaccurate financial reporting and potential misstatement of the financial statements such that they are not in accordance with accounting principles generally accepted in the United States of America. In addition, the Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification as a Repeat Finding Condition is a repeat finding - see 2018-006. Recommendation We recommend that the Center implement policies and procedures that allow for the timely reconciliation of accounts on a monthly basis. In addition, the Center should establish controls to ensure that all accounting records are analyzed and proper support is available in order to ensure that the financial statement audit is submitted on a timely basis to the federal government.

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