EIN: 270052697
UEI: D1MWC7E2K444
Audited by: CliftonLarsonAllen LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 4, 2025. 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 September 4, 2025 (361 days ago).
What is a management decision? →FAC accepted this audit on September 24, 2023 — management decision was due March 24, 2024.
During our testing, we noted the Health Center did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. We also noted the Health Center's conflict of interest policy did not meet all the requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Health Center had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Based on our testing, the Health Center followed the policy in place, but the micro purchase threshold requiring multiple quotes or documentation of sole source procurement under the policy is set at $50,000, where the requirement is $10,000 unless specific steps have been taken to certify a higher threshold. Similarly, the Health Center has a conflict of interest policy and procedures in place, but the language does not meet the specific requirements of Uniform Guidance. Noted both policies to be updated to be in compliance with Uniform Guidance compliance near year-end in response to the prior year audit finding, but due to the timing policies in place for majority of year were not in compliance. Cause: The Health Center had not yet updated their procurement and conflict of interest policies to meet Uniform Guidance requirements. Effect: Without updates to procurement and conflict of interest policies over these compliance requirements the Health Center is not fully compliant with Uniform Guidance requirements. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-002 was a significant deficiency. Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Views of responsible officials: There is no disagreement with the audit finding. Policies were updated near the end of 2022 to be in compliance with requirements.
Show full finding ▾Hide full finding ▴2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations (CFR) section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. CFR 200.318 also states specific requirements for conflict of interest policies and procedures non-federal entities must maintain, including specifically addressing conflicts related to contracts supported by federal awards. Condition: During our testing, we noted the Health Center did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. We also noted the Health Center's conflict of interest policy did not meet all the requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Health Center had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Based on our testing, the Health Center followed the policy in place, but the micro purchase threshold requiring multiple quotes or documentation of sole source procurement under the policy is set at $50,000, where the requirement is $10,000 unless specific steps have been taken to certify a higher threshold. Similarly, the Health Center has a conflict of interest policy and procedures in place, but the language does not meet the specific requirements of Uniform Guidance. Noted both policies to be updated to be in compliance with Uniform Guidance compliance near year-end in response to the prior year audit finding, but due to the timing policies in place for majority of year were not in compliance. Cause: The Health Center had not yet updated their procurement and conflict of interest policies to meet Uniform Guidance requirements. Effect: Without updates to procurement and conflict of interest policies over these compliance requirements the Health Center is not fully compliant with Uniform Guidance requirements. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-002 was a significant deficiency. Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Views of responsible officials: There is no disagreement with the audit finding. Policies were updated near the end of 2022 to be in compliance with requirements.
U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement and Conflict of Interest Policies were recently revised in Oct 2022 and Dec 2022 ahead of HRSA operational site visit to meet Uniform Guidance requirements. Staff have been trained on requirements related to the procurement thresholds and documentation standards. Documentation and discussion of procurement standards will be captured per that policy, with board action and discussion. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022
2021-002
During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of three disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-003 was a significant deficiency. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding. Policy and procedures were put in place late in 2022 in response to the prior year audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Health Center to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Health Center should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred, and retain documentation to support those procedures are being followed. Condition: During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of three disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-003 was a significant deficiency. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding. Policy and procedures were put in place late in 2022 in response to the prior year audit finding.
U.S. Department of Health and Human Services 2022-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement policy was revised in Oct 2022, with staff trained on requirements related to testing of vendors related to suspension and disbarment. Staff will retain documentation per the revised policy under UFM?s record retention policy. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022
2021-003
FAC accepted this audit on December 21, 2022 — management decision was due June 21, 2023.
During our testing, we noted the Health Center did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. We also noted the Health Center's conflict of interest policy did not meet all the requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Health Center had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Based on our testing, the Health Center followed the policy in place, but the micro purchase threshold requiring multiple quotes or documentation of sole source procurement under the policy is set at $50,000, where the requirement is $10,000 unless specific steps have been taken to certify a higher threshold. Similarly, the Health Center has a conflict of interest policy and procedures in place, but the language does not meet the specific requirements of Uniform Guidance. Cause: The Health Center had not yet updated their procurement and conflict of interest policies to meet Uniform Guidance requirements. Effect: Without updates to procurement and conflict of interest policies over these compliance requirements the Health Center is not fully compliant with Uniform Guidance requirements. Repeat finding: Not a repeat finding Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations (CFR) section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. CFR 200.318 also states specific requirements for conflict of interest policies and procedures non-federal entities must maintain, including specifically addressing conflicts related to contracts supported by federal awards. Condition: During our testing, we noted the Health Center did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. We also noted the Health Center's conflict of interest policy did not meet all the requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Health Center had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Based on our testing, the Health Center followed the policy in place, but the micro purchase threshold requiring multiple quotes or documentation of sole source procurement under the policy is set at $50,000, where the requirement is $10,000 unless specific steps have been taken to certify a higher threshold. Similarly, the Health Center has a conflict of interest policy and procedures in place, but the language does not meet the specific requirements of Uniform Guidance. Cause: The Health Center had not yet updated their procurement and conflict of interest policies to meet Uniform Guidance requirements. Effect: Without updates to procurement and conflict of interest policies over these compliance requirements the Health Center is not fully compliant with Uniform Guidance requirements. Repeat finding: Not a repeat finding Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.
2021-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement and Conflict of Interest Policies were recently revised in Oct 2022 and Dec 2022 ahead of HRSA operational site visit to meet Uniform Guidance requirements. Staff have been trained on requirements related to the procurement thresholds and documentation standards. Documentation and discussion of procurement standards will be captured per that policy, with board action and discussion. Name(s) of the contact person(s) responsible for corrective action: Eric Blum, CFO Planned completion date for corrective action plan: 12/20/2022
During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of one disbursement transaction greater than $25,000 was selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: Not a repeat finding. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Health Center to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Health Center should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred, and retain documentation to support those procedures are being followed. Condition: During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of one disbursement transaction greater than $25,000 was selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: Not a repeat finding. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding.
2021-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement policy was revised in Oct 2022, with staff trained on requirements related to testing of vendors related to suspension and disbarment. Staff will retain documentation per the revised policy under UFM?s record retention policy. Name(s) of the contact person(s) responsible for corrective action: Eric Blum, CFO Planned completion date for corrective action plan: 12/20/2022
FAC accepted this audit on June 16, 2021 — management decision was due December 16, 2021.
FAC accepted this audit on June 25, 2020 — management decision was due December 25, 2020.
FAC accepted this audit on June 10, 2019 — management decision was due December 10, 2019.
FAC accepted this audit on May 22, 2018 — management decision was due November 22, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-003
FAC accepted this audit on May 15, 2017 — management decision was due November 15, 2017.
GSA_MIGRATION
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