Community Health Partnership of Illinois, Inc.Non-Profit

Community Health Partnership of Illinois, Inc. did not file their completed Single Audit report for the year ended January 31st, 2021, within the required 9 months from year-end.

Community Health Partnership of Illinois, Inc. did not minimize the time between drawdown and disbursement of Federal funds in accordance with Federal regulations. The program had excess cash on hand for more than twelve (12) months.

FINDING NO. 2021-003: Ineffective Internal Controls Over Sliding Fee Revenues Federal Program Name Health Center Program Project No. 2H80CS00748-19-11, 1H8CCS34434-01-00, 1H8DCS36120-01-00, 1H8ECS38736-01-00 CFDA # 93.224 Federal Agency Department of Health and Human Services CRITERIA/SPECIFIC REQUIREMENT: The Organization is responsible for establishing and maintaining an internal control system over sliding fee and clinic service eligibility requirements. Specifically, 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 as follows: ? Sliding fee discounts are applied to fees for health center services provided to all individuals an families with annual incomes at or below 200 percent of the Federal Poverty Guidelines (PFG); ? A full discount is applied to fees for health center services provided to individuals and families with annual incomes at or below 100 percent of the FGP, or the health center only applies a nominal charge; ? Fees for health center services are discounted based on graduations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FGP; and ? No sliding fee discount is applied to fees for health center services provided to individuals and families within 200 percent or more of the FGP. CONDITION: During the compliance testing of the Uniform Guidance ?Special Tests and Provisions ? Sliding Fee Applications? requirements, we noted the following exceptions: ? Five (5) instances in which the family registration forms had not been received for the current year sliding fee applications. QUESTIONED COSTS: N/A CONTEXT: Exceptions were noted in 5 of the 40 sliding fee patients tested. EFFECT: Lack of effective internal control procedures could result in unintentional errors that may not be detected in a timely manner by employees in the normal course of performing their assigned duties. CAUSE: Lack of oversight over slide fee application due largely in part to changes in personnel, staffing shortages, and other challenges associated with the COVID-19 pandemic. RECOMMENDATION: Management should take steps to ensure procedures over sliding fee applications are properly designed and operating effectively. MANAGEMENT?S RESPONSE: Community Health Partnership of Illinois, Inc. (CHP)?s new CEO joined the organization 1/2020, one month before the nationwide need to redesign the Organization to fit with the new pandemic guidance. During this time, it became evident that the Organization did not have sufficient accounting staff. Once determined, a plan was put in place to add to the financial staffing, especially needed with the observed new levels of funding arising from the pandemic and its related impact. Efforts were made to identify and recruit additional support staff without success during this time, but the challenges increased as the pandemic widened. By November 2020, CHP?s Director of Finance, a staff of 20 years, resigned and went to part-time status working fully remotely from Indiana. With the change in key staff, shortage of skilled staff, the pandemic, illness resulting in frequent call offs due to the pandemic, the difficulty recruiting during the pandemic, the incompleteness of accounting reporting and recordings caused by resignations, and staffing shortages, complete financial reporting for the period was not achieved. CHP was successful in hiring a new Director of Finance by March of 2021 and soon thereafter the Health Resource and Service Administration (HRSA), CHP?s major funding source, announced the need to accomplish CHPs, now due, three-year Virtual Operational Site Visit (VOSV) Audit. Both audits (HRSA and the independent financial statement audit by Kemper CPA) being due at the same time would have caused undue stress for the limited and new personnel in place during the time of a worldwide pandemic. Both audits required similar time and commitments from a meager staff. With new staff, gap in other key staff, gap in the full closure of financial reporting, and the need for additional staff; CHP?s decision was to request additional time to complete the independent audit by Kemper. This request was granted and shortly thereafter CHP began submission and review of prior work to compile and submit accurate reports. Similar ask was made of the HRSA audit team for extension but was not granted. The same or more levels of efforts were needed for both types of reviews and so CHP made the best decision knowing that the Federal government guides all around the flexibility of the challenges the pandemic brings and the need to support organizations during this time. As a result, the situational aftermath of the decision to request much needed audit time extension, the learning curve of the new director, the newness of staff, shortage of staff, COVID-19 illness, frequency of call offs, change in key personnel, fears around the COVID-19 pandemic, and the incomplete work from prior key leader in finance due to resignation created additional gaps and delays for the timely adjustments and submission of accurate reports.

FINDING NO. 2021-004: Internal Controls Over Expenditure Report Preparation Federal Program Name Health Center Program Project No. 2H80CS00748-19-11, 1H8CCS34434-01-00, 1H8DCS36120-01-00, 1H8ECS38736-01-00 CFDA # 93.224 Federal Agency Department of Health and Human Services CRITERIA/SPECIFIC REQUIREMENT: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-federal entity?s financial management system, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of the reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to federal statutes, regulations, and the terms and conditions of the federal award. Health Resources & Services Administration (HRSA) also implements various quarterly and annual reporting deadlines at the grant agency level. CONDITION: The Organization?s internal controls over the preparation and review of grant expenditure reports were not properly followed during the current fiscal year. Certain expenditure reports submitted to HRSA did not contain the correct expenditures claimed and were not timely filed: ? The Uniform Data System (UDS) report was due by February 15, 2021 but was not submitted until March 19, 2021. ? The quarterly Federal Financial Report (FFR) is due to HRSA 30 days after quarter end. One (1) report was filed one day late. ? The Annual SF-425, Federal Financial Report was submitted timely, but the expenditures claimed on the report did not reflect actual expenditures reimbursed. QUESTIONED COSTS: N/A CONTEXT: Exceptions were noted in 3 of the 6 reports tested. EFFECT: Untimely or inaccurate expenditure reporting could result in either overstatements or understatements of expenditures to granting agencies. A return of grant funds could be requested from the granting agencies. CAUSE: The errors were caused by a lack of sufficient supervisory review of expenditure reports due largely in part to changes in key financial personnel, staffing shortages, and other challenges associated with the COVID-19 pandemic. RECOMMENDATION: The Organization should create a system of internal controls to ensure all expenditure reports are submitted accurately and timely filed. MANAGEMENT?S RESPONSE: Community Health Partnership of Illinois, Inc. (CHP)?s new CEO joined the organization 1/2020, one month before the nationwide need to redesign the Organization to fit with the new pandemic guidance. During this time, it became evident that the Organization did not have sufficient accounting staff. Once determined, a plan was put in place to add to the financial staffing, especially needed with the observed new levels of funding arising from the pandemic and its related impact. Efforts were made to identify and recruit additional support staff without success during this time, but the challenges increased as the pandemic widened. By November 2020, CHP?s Director of Finance, a staff of 20 years, resigned and went to part-time status working fully remotely from Indiana. With the change in key staff, shortage of skilled staff, the pandemic, illness resulting in frequent call offs due to the pandemic, the difficulty recruiting during the pandemic, the incompleteness of accounting reporting and recordings caused by resignations, and staffing shortages, complete financial reporting for the period was not achieved. CHP was successful in hiring a new Director of Finance by March of 2021 and soon thereafter the Health Resource and Service Administration (HRSA), CHP?s major funding source, announced the need to accomplish CHPs, now due, three-year Virtual Operational Site Visit (VOSV) Audit. Both audits (HRSA and the independent financial statement audit by Kemper CPA) being due at the same time would have caused undue stress for the limited and new personnel in place during the time of a worldwide pandemic. Both audits required similar time and commitments from a meager staff. With new staff, gap in other key staff, gap in the full closure of financial reporting, and the need for additional staff; CHP?s decision was to request additional time to complete the independent audit by Kemper. This request was granted and shortly thereafter CHP began submission and review of prior work to compile and submit accurate reports. Similar ask was made of the HRSA audit team for extension but was not granted. The same or more levels of efforts were needed for both types of reviews and so CHP made the best decision knowing that the Federal government guides all around the flexibility of the challenges the pandemic brings and the need to support organizations during this time. As a result, the situational aftermath of the decision to request much needed audit time extension, the learning curve of the new director, the newness of staff, shortage of staff, COVID-19 illness, frequency of call offs, change in key personnel, fears around the COVID-19 pandemic, and the incomplete work from prior key leader in finance due to resignation created additional gaps and delays for the timely adjustments and submission of accurate reports.