Bay Area Community Health

ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: C Cash Management Repeat Finding: No Criteria: The compliance supplement requires organizations receiving federal funds to establish controls and procedures that would minimize the amount of time between drawdowns and the disbursements of grant funds. Finding/ Condition: Federal grant funds were received prior to obligation/disbursement of funds. Questioned Cost: None. Effect: Reimbursement occurred before needed for disbursement purposes. Cause: There was significant turnover in key accounting staff positions during the year and a misunderstanding of federal regulations on drawdowns. Repeat Finding: No. Recommendation: We recommend training for staff to ensure cash management requirements are followed. Management should track the status of the federally funded cash disbursements against the need to draw down funds on related grants. Views of Responsible Officials and Corrective Action Plan: The Center has refined its drawdown checklist to ensure that key accounting and grant management staff consistently monitor cash disbursements and align them with the timely drawdown of associated grant funds. In addition, the Center will conduct retraining for finance and grant management personnel on the updated drawdown checklist and revised procedures to strengthen compliance and oversight.

ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N Special Tests and Provisions Repeat Finding: No Criteria: Federal grant compliance provisions require that the Center correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Center is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 71 tested items four patients received the incorrect sliding fee discount based on the family size and income level or the applications used to receive the sliding fee discount were expired. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Center providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and Center policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements. The Center should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: All Front Desk Staff have been retrained on the 2026 Sliding Fee Discount Program. Additionally, emphasis on applying the Sliding Fee Discount program has been incorporated in the onboarding process. Going forward, Compliance and Finance will conduct quarterly audits of samples from the Sliding Fee Discount Program.

2025-004 Procurement Suspension and Debarment ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: I Procurement Suspension and Debarment Repeat Finding: No Criteria: Per 45 CFR 75.327(i), a non-Federal entity who receives HHS awards must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Finding/Condition: During our testing of the Center’s procurement transactions for federal purchases (25 samples), we noted the Center could not provide a sufficient history of the procurement decisions including the method of procurement and contractor selection. Questioned Cost: None. Effect: The entity is not in compliance with 45 CFR 75.327 for procurement. Cause: The Center did not have procedures in place for procurement in retaining the required documentation detailing the history of the procurement. Recommendation: We recommend the Center develop procedures for procurement with federal funds. Views of Responsible Officials and Corrective Action Plan: The Center continues to have and utilize Federal Procurement Policies and Procedures to comply with 45 CFR 75.327. Due to key staff turnover in the Finance Department, they failed to access and present essential historical knowledge of the Center’s procurement process. The Center’s procurement information is held in multiple separate systems (the shared drive system with access by CFO, controller, manager, Senior Accountant, etc.) The Center understands that the procurement process can be better refined by creating one centralized finance cataloged database to maintain all historical information regarding the procurement process. The Center has created a central database to store (catalog) all documents and communications relating to the procurement process which will allow the information to be recognized and pulled with ease.

2022-001 Sliding Fee Discount Determination ALN: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Repeat Finding: No Criteria: Federal grant compliance provisions require that the Center correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Center is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, patient information was inadequate to determine the proper sliding fee discount or the patient was given incorrect discounts based on information provided. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Center providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and Center policies by employees involved in sliding fee determination. Recommendation: Training should be provided to employees on the sliding fee program requirements. The Center should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: The Center agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 33.

2021-001 Compliance Over Reporting CFDA Number: 93.224 Program: Community Health Center Cluster Compliance Requirement: (L) Reporting Criteria: Pursuant to the reporting requirement set forth by the Department of Health and Human Services, the Center is required to file the quarterly Federal Financial Report (FFR) within 30 days of the end of the quarter. Finding/ Condition: During our reporting period, we noted that the Center submitted the quarterly FFR late for two quarters. Questioned Cost: None. Effect: The delay in submitting the required report may lead to the granting agency to impose temporary restrictions on the drawdown process. Cause: The reporting requirement was not included on a quarterly reminder checklist. Recommendation: We recommend the Center file the required quarterly FFR in a timely manner. Views of Responsible Officials and Corrective Action Plan: The Center agrees with the finding and has implemented additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 32.