DETROIT HEALTH CARE FOR THE HOMELESS DBA ADVANTAGE HEALTH CENTERSNon-Profit

Criteria – Uniform Guidance (2 CFR §200.305) requires that non-federal entities establish and maintain written procedures to minimize the time elapsing between the transfer of federal funds from the U.S. Treasury and the disbursement of those funds for allowable program expenditures. In addition, entities must maintain adequate documentation to support all drawdowns and ensure that amounts requested are based on actual, allowable costs incurred. Condition and Description – During our audit, we identified deficiencies in the Organization’s compliance with federal cash management requirements and internal controls over reporting of federal expenditures. Specifically, documentation supporting certain drawdowns of federal funds was not consistently maintained. However, the total drawdowns did not exceed eligible expenses. In addition, we noted timing differences between when expenses were recognized in the financial statements and when related drawdowns were requested and reported to the federal government. These conditions create the risk that federal funds may not be drawn down in alignment with actual expenditures, resulting in temporary over- or under-drawdowns, increasing the likelihood of noncompliance with Uniform Guidance requirements and misstatements of federal program expenditures. Questioned Costs – Unknown. Cause/Effect – Drawdowns were not consistently reconciled to underlying expenses, and supporting documentation was incomplete. Timing differences between expenditures and drawdowns were not addressed, creating the risk of temporary over- or under-drawdowns and noncompliance with federal cash management requirements.

Criteria – Uniform Guidance (2 CFR §200.510(b)) requires auditees to prepare a SEFA that is accurate, complete, and supported by the accounting records. Condition and Description – The Organization did not prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as required by Uniform Guidance. Certain federal awards expended during the year were omitted, and amounts reported did not reconcile to the accounting records, resulting in an incomplete representation of federal expenditures subject to audit. Questioned Costs – Unknown. Cause/Effect –. Controls over SEFA preparation were insufficient to ensure all federal awards were identified and reconciled to the accounting records. As a result, certain expenditures were omitted or misstated, increasing the risk of incomplete or inaccurate reporting under Uniform Guidance.

Criteria – Uniform Guidance (2 CFR §200.512) requires that auditees submit the Single Audit reporting package to the Federal Audit Clearinghouse within nine months after the end of the audit period. Condition and Description – The Organization did not submit its Single Audit reporting package to the Federal Audit Clearinghouse within the nine-month deadline required by Uniform Guidance. The package, which includes the SEFA, Data Collection Form, audit report, summary of prior audit findings, and corrective action plan, was filed after the due date. Questioned Costs – None. Cause/Effect – Due to changes in the accounting personnel during the year, the books were not closed in a timely manner, and various adjustments were made to the general ledger in conjunction of the audit which resulted in delay in completion of the report. Untimely filing resulted in noncompliance with Uniform Guidance reporting requirements and potential federal oversight concerns.

Criteria – The HRSA Compliance Manual requires federally qualified health centers (FQHCs) to establish and maintain a sliding fee discount program to ensure that services are accessible to patients regardless of their ability to pay. Eligibility must be based solely on income and family size, supported by appropriate documentation. Under Uniform Guidance (2 CFR §200.303), non-federal entities must establish and maintain effective internal controls over compliance with federal statutes, regulations, and program requirements. The OMB Compliance Supplement (Part 4, Health Center Program Cluster) further emphasizes that health centers must document income and family size to properly apply sliding fee discounts and must consistently implement the approved discount schedule. Condition and Description – During our testing of compliance with the sliding fee discount program, we identified deficiencies in the application and documentation of the sliding fee discount schedule. Of 10 patient encounters selected for review, 6 patient files did not contain a registration form to support determination of sliding fee eligibility. In addition, although the Organization’s policy requires retention of two paystubs for each patient to verify income, only one paystub was maintained in several patient records. Further, 4 patient files reviewed did not contain documentation of household member information, which is required to calculate family size for eligibility determination. These deficiencies reflect noncompliance with the Organization’s policies and federal program requirements and may result in patients not being charged in accordance with their ability to pay. Questioned Costs – Unknown. Cause/Effect –. The Organization did not obtain or retain adequate documentation of patient income, family size, and registration forms to support eligibility determinations. Without this information, compliance with the sliding fee discount requirements could not be demonstrated, creating the risk that discounts were not applied appropriately and federal program requirements were not met

Criteria - In accordance with the OMB Compliance Supplement and the grant agreement, the Organization is required to submit the PHCP Progress Report and SF-428 by the specified due date. Condition and Description - During our audit, we noted that the final SF-428 and PHCP Progress Report for the period ended December 31, 2023 was submitted after the due date. Questioned Costs - Unknown. Cause/Effect - The Organization failed to meet the reporting requirements outlined in the grant agreement and compliance supplement.

Criteria - As per 45 CFR 75.305, a health center should have written procedures that minimize the time elapsing between the transfer of Federal award funds from HHS and the disbursement of these funds by the health center. Condition and Description - During our audit we noted that appropriate documents supporting the drawdown of funds not maintained by the Organization, and further one of the drawdown was interchanged between two grants. Although, the total drawdowns were within the eligible expenses incurred. Questioned Costs - Unkown. Cause/Effect - The Organization has not complied with the requirements as per the HRSA compliance manual and OMB Compliance Supplement.

Criteria - 2CFR Part 200 requires an auditee to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). Condition and Description - During the audit, we noted that the SEFA did not include all the federal grants received during the year. Questioned Costs - Unkown. Cause/Effect - The SEFA was not accurately stated as a result of not identifying certain federal award expenditures.

Criteria - As per Title 2 US Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, the Agency is required to submit a Single Audit within nine months after the end of its audit period. Condition and Description - Entities that expend $750,000 or more in federal awards are required to comply with the provisions of Title 2 US Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). As part of the requirement, the Agency is required to submit a Single Auidt within nine months after the end of its audit period. The Reporting package shall include 1) SF-SAC Data Collection Form for Reporting on Audits of States, Local Governments, and Non-Profit Organizations, 2) Summary of prior audit findings, 3) Single Audit Report, and 4) Corrective Action Plans. Questioned Costs - Unkown. Cause/Effect - The Organization has not complied with the provisions of Tittle 2 US Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).

As per the HRSA compliance manual, the health center must prepare a sliding fee discount schedule to be applied to the payment of fees based on the patient's ability to pay. ? For 3 out of 10 encounters tested, the sliding fee adjustment was not made as per the sliding fee discount schedule.

As per the OMB compliance supplement and the HRSA compliance manual, the Organization must submit the final SF-425 within the due date. During our audit, we noted that the final SF-425 for the period ended December 31, 2022 was submitted after the due date.

As per 45 CFR 75.305, a health center should have written procedures that minimize the time elapsing between the transfer of Federal award funds from HHS and the disbursement of these funds by the health center. During our audit we noted that appropriate documents supporting the drawdown of funds were not maintained by the organization, although, the total drawdowns were within the eligible expenses incurred.

2CFR Part 200 requires an auditee to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). During the audit, we noted that the SEFA did not include all the federal grants received during the year. It was noted that the Organization does not have a system in place to correctly identify the source of funds received.

? For 5 out of 10 encounters tested, the sliding fee adjustment was not made as per the sliding fee discount schedule. ? For 1 out of 10 encounters, supporting documents were not provided to verify that the sliding fee adjustment was made based on the patient?s ability to pay.

During our audit, we noted that the quarterly SF-425 for the quarter ended March 31, 2021 was submitted 4 days late.

? For 2 out of 40 samples selected for payroll testing, the pay rate change form was not signed by an authorized personnel. ? For 4 out of 40 samples, the support to verify the approved pay rate was not provided for review. ? For 6 out of 40 samples, the personnel files were not updated with all the required documents as per organization?s policy.

During our audit we noted that appropriate documents supporting the drawdown of funds were not maintained by the organization, although, the total drawdowns were within the eligible expenses incurred.

During our audit we noted that the supporting documents to verify information reported on Table 5 of the UDS report regarding the number of encounters was not available for review. Also, information reported on Table 8 did not agree to the underlying supporting documents.

During our audit we noted that the Board of Directors did not have a patient majority.

During the audit, we noted that the SEFA did not include all the federal grants received during the year. It was noted that the Organization does not have a system in place to correctly identify the source of funds received.

? For 4 out of 10 encounters tested, the sliding fee adjustment was not made as per the sliding fee discount schedule. ? For 1 out of 10 encounters, supporting documents were not provided to verify that the sliding fee adjustment was made based on the patient?s ability to pay.

During our audit, we noted that the quarterly SF-425 for the quarter ended June 30, 2020 was submitted 4 days late.

? For 7 out of 45 samples selected for payroll testing, the pay rate change form was not signed by an authorized personnel. ? For 1 out of 45 samples, the support to verify the approved pay rate was not provided for review.

Criteria ? 2CFR Part 200 requires an auditee to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). Condition and Description ? During the audit, we noted that the SEFA did not include all the federal grants received during the year. It was noted that the Organization does not have a system in place to correctly identify the source of funds received.

Criteria ? As per 45 CFR 75.305, a health center should have written procedures that minimize the time elapsing between the transfer of Federal award funds from HHS and the disbursement of these funds by the health center. Condition and Description ? During our audit, we noted that for the fiscal year 2019, supporting documents to verify the drawdown of funds were provided, however, these were incomplete. Subsequent to year end, the Organization revised the drawdown process to ensure that federal drawdowns are based on the actual expenditures incurred.

Criteria ? As per the HRSA compliance manual, the health center must prepare a sliding fee discount schedule to be applied to the payment of fees based on the patient's ability to pay. Condition and Description ? ? For 2 out of 10 encounters tested, a sliding fee adjustment was not made as per the sliding fee discount schedule. ? For 3 out of 10 encounters tested, adequate documentation was not maintained to verify that the sliding fee discount was applied based on the patient?s ability to pay.

Criteria ? As per the OMB compliance supplement and the HRSA compliance manual, the Organization must submit the quarterly SF-425 report within 30 days from the end of the quarter. Condition and Description ? During our audit, we noted that the quarterly SF-425 for the quarter ended June 30, 2019 was submitted 1 day late

Criteria ? As per the HRSA compliance manual and OMB compliance supplement, the health center must complete and submit the Uniform Data System (UDS) report annually. Condition and Description ? During the review of UDS report, immaterial variances were noted between the information reported on Table 5 of the UDS report regarding the number of encounters for 2019 and the underlying supporting documentation.

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