The Osborn Family Health Center, Inc.

Item 2022-001 - Proper Documentation of Timely Verification of Suspension and Debarment: U.S. Department of Health and Human Services, Health Center Program Cluster: Assistance Listing Number 93.224/ 93.527) - Procurement, Suspension and Debarment (Significant Deficiency) Criteria: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Statement of condition: The Center was unable to provide any evidence of their verification of whether 35 sample employees whose salaries are charged to the Health Center Program are suspended or debarred. Cause: A transition in the employees performing the control caused data loss. Effect: This condition may lead to noncompliance with suspension and debarment requirements and may also lead to questioned costs. Questioned costs: None noted. Context: 35 out of the 60 samples tested did not have evidence of verification of suspension and debarment. Identification as a repeat finding: This is a repeat finding and was reported as item 2021-004 in the 2021 Summary of Findings and Questioned Costs. Recommendation: We recommend that the Center strictly implement its control procedures in relation to the verification of employees' suspension or debarment and that the Center ensure that evidence of performance of such control be maintained. Management response: Management concurs with the finding and has already established a process for ensuring that documentation for the verification of employees for suspension and debarment is maintained.

Item 2021-002 Maintain accurate and timely program-level financial reporting: U.S. Department of Health and Human Services, Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), COVID-19 Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), and Grants for New and Expanded Services under the Health Care Center Program (Assistance Listing Number 93.527). Criteria: 2 CR Part 200, Subpart E (Cost Principles) require that for costs to be allowable under Federal awards, costs should be necessary and reasonable for the performance of the federal award and allocable thereto, should ?conform to any limitations or exclusions set forth in 2 CFR Part 200, Subpart E; be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity; be accorded consistent treatment; be in accordance with generally accepted accounting principles; not be included as a cost or used to meet cost-sharing or matching requirements of any other federally financed program in either the current or prior period; and be adequately documented.? In order to document compliance with the above requirements, it is best practice to maintain an accurate program-level financial reporting on a timely manner. Statement of Condition: The Center?s general ledger is not designed to account for transactions at the program level by natural classification of expenses. The Center?s monthly program-level profit and loss analysis is prepared using Microsoft Excel and does not reconcile to the trial balance. Cause: The Center did not have sufficient resources to redesign its chart of accounts and create a program-level financial report from the general ledger. Effect: This condition may lead to inaccurate financial reporting at the program level. It may cause the Center to not fully utilize the available federal or state awards. It may also lead to unsupported or inaccurate drawdowns from federal awards. Recommendation: We recommend that the Center redesign its chart of accounts to establish program-level sub-accounts. We also recommend that the Center prepare and review program-level profit and loss statements on a monthly basis and compare such to the budget to ensure that the Center is able to fully utilize its awards. Management Response: Management concurs with the finding and will ensure that the chart of accounts are redesigned to establish program-level accounts.

Item 2021-003 Timely and Accurate Submission of Federal Financial Reports: U.S. Department of Health and Human Services, Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), COVID-19 Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), and Grants for New and Expanded Services under the Health Care Center Program (Assistance Listing Number 93.527) Criteria: Grantees under the Health Center Program are required to submit quarterly and annual Federal Financial Reports (FFRs). Statement of Condition: The Center failed to submit its quarterly FFR covering the quarter ended September 30, 2020. The quarterly FFR for the quarter ended June 30, 2021 was not filed timely. Cause: The Center did not have sufficient resources to ensure that the quarterly FFR for the quarter ended September 30, 2020 be completed and submitted and for the quarterly FFR for the quarter ended June 30, 2021 be completed and submitted timely. Effect: This condition may lead to noncompliance with reporting requirements. Recommendation: We recommend that the Center create a calendar indicating all reporting due dates and assign a responsible personnel to monitor and ensure that all required reports are completed and submitted timely. Management Response: Management concurs with the finding and plans to create a calendar indicating all reporting due dates. Management will also identify and assign the personnel responsible for ensuring that each report is completed and submitted timely.

Item 2021-004 Timely Verification of Suspension and Debarment: U.S. Department of Health and Human Services, Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), COVID-19 Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) (Assistance Listing Number 93.224), and Grants for New and Expanded Services under the Health Care Center Program (Assistance Listing Number 93.527) Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Statement of Condition: The Center?s verification of whether two contractors and certain vendors for the Health Center Program are suspended or debarred was done late. Cause: The Center became aware of the requirement relating to suspension and debarment after it has already entered into transactions with such contractors and vendors. Effect: This condition may lead to noncompliance with suspension and debarment requirements and may also lead to questioned costs. Recommendation: We recommend that the Center establish a process for verifying whether contractors or vendors are suspended or debarred or otherwise excluded from participating in covered transactions prior to entering into any transactions with contractors or vendors. Management Response: Management concurs with the finding and has already established a process for verifying all employees, vendors and contractors for suspension and debarment on a timely basis.