Primecare Community Health, Inc

Information on the Federal Program Federal Program Name: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Federal Assistance Listing Title and Number: Consolidated Health Centers (Community Health Centers), 93.224; Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program, 93.527 Criteria or Specific Requirement: Under Uniform Guidance compliance requirements for Procurement (2 CFR 200.318(i)), contract files must be 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. In cases where competition was limited, such as scenarios where specific qualifications and competence are required, the files should provide evidence that the limitation on competition was justified. Also, the Uniform Guidance compliance requirements for Procurement (Appendix II to Part 200), require that Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions enumerated in Appendix II to Part 200 (A) to (L). Condition: The Organization entered to a purchase contract with a vendor that is considered a sole source purchase agreement. The Organization did not maintain and retain appropriate documentation to justify the limitation on competition related to the vendor selection and why the purchase is a sole source purchase agreement. The sole source purchase agreement entered also did not include the contract provision required by Appendix II to Part 200. Questioned Costs: $0 Context: During our testing of procurement requirements, the sole vendor purchase charged to the grant did not have appropriate documentation to evidence the basis of vendor selection or documentation to justify the limitation on competition vendor selection and why the purchase is a sole source purchase agreement. Also, the sole source purchase agreement does not contain the provisions enumerated in Appendix II to Part 200 (A) to (L). Effect: Vendor purchase was made without appropriate documentation to comply with Uniform Guidance requirements. Also, contracts were entered into and approved without the require provision of Appendix II to Part 200 of the Uniform Guidance. Cause: Adequate supporting documentation on the procurement was not obtained or maintained within vendor files including the justification on the limitation on competition on vendor selection. The vendor contract does not contain the necessary contract provision and language required by the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Organization revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions including the justification on the limitation on competition on vendor selection for sole source contract arrangement. We also recommend the Organization to include the contract provision required by Appendix II to Part 200 CFR on all its contracts. Views of responsible officials and planned corrective actions: See corrective action plan prepared by management attached.

Information on the Federal Program Federal Program Name: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Federal Assistance Listing Title and Number: Consolidated Health Centers (Community Health Centers), 93.224; Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program, 93.527 Criteria or Specific Requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not properly apply the sliding fee scale discount assigned to patients.Questioned Costs: $0 Context: For 4 out of 25 samples tested, the Organization incorrectly applied sliding fee scale discount assigned to patient, resulting to patients billed for the incorrect amounts. Effect: Patients received the incorrect sliding fee discount that they were eligible for based on income. Cause: The inaccuracies in the application of the sliding fee program discounts appear to be due to inadequate oversight and review. Repeat Finding: No Recommendation: The Organization should strengthen processes surrounding monitoring and self-review of the sliding fee discount application and determination. Management should periodically audit the sliding fee of patient encounters to ensure that discounts are appropriately determined and calculated. Views of responsible officials and planned corrective actions: See corrective action plan prepared by management attached.

U.S. Department of Health and Human Services: Health Center Program Cluster CFDA 93.224, 93.527 ConditionThe Organization inaccurately reported an amount on the Uniform Data System (UDS) report submitted for the year ended December 31, 2020. Grantees that receive multiple awards (in addition to or other than Community Health Centers (CHC) funding) must complete a Universal Report for the combined grants.During our audit, we noted differences in the total accrued Bureau of Primary Health Care (BPHC) Section 330 grants drawn-down for the period from January 1 through December 31, 2020. The amounts originally reported on the UDS report did not agree to amounts reported on the Federal Payment System data, the Organization?s records, and audited consolidated financialstatements. The amount reported under the Health Center grant included COVID-19 supplemental grant funds required to be reported separately. The amounts reported for COVID- 19 supplemental grants represented the total amounts awarded as opposed to the amounts drawn down by the Organization during the year ended December 31, 2020. CriteriaAccording to 42 CFR Section 51c.303(j) a community health center must establish basic statistical data, cost accounting, management information, and reporting or monitoring systems which shall enable the center to provide such statistics and other information as required relating to the center?s costs of operation, patterns of utilization of services, and the availability,accessibility, and acceptability of its services and to make such reports in a timely manner.Cause and EffectIneffective controls, including insufficient review and approval, over reporting resulted in an incorrect amount reported on the UDS report for the BPHC grants.RecommendationWe recommend that management strengthen controls over the UDS report, including reconciliation of reported data to supporting schedules and formal review and approval of controls before the report is submitted.Views of Responsible Officials and Planned Corrective ActionsWe agree with the auditors? comments that the UDS report did not accurately reflect the amounts drawn down from the Federal Payment System in 2020. Current management is new to the Organization so the following actions will be taken to ensure that the situation is improved in the future. We will have the Organization?s Grants Manager export the amounts drawn down fromthe Federal Payment Management System, and management will reconcile the amounts to our trial balance, and ensure that the correct amount is reported on UDS. Using the information from the Federal Payment Management System, we will also ensure that we break out all COVID-19 supplemental grants from the Health Center grant. We will then have the Organization?s GrantsManager confirm that the amounts on the UDS report agree with the Federal Payment Management System. We will submit this correctly on the 2021 UDS Report. Prior Year Findings ? Financial Statement FindingsNonePrior Year Findings ? Major Federal Award Programs Findings andQuestioned CostsNone