EIN: 391759404
UEI: M328B1MG1MX1
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 May 4, 2026. 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 November 4, 2026 (66 days from today).
What is a management decision? →The Clinic was unable to provide documentation that a formal review and approval process had occurred prior to initiating drawdowns via the payment management system. Questioned Costs: None Context: This condition was identified during the review and testing of drawdowns as part of testing cash management. Cause: The Clinic has a limited number of resources in its finance department and as a result has incorporated the executive director into the review process. However, documentation was not created and maintained to shown that a formal review and approval had occurred prior to initiation drawdowns. Effect: The lack of documented review increases the risk that noncompliance with federal requirements could occur and not be prevented or detected in a timely manner. Repeat Finding: No. Recommendation: We recommend the Clinic develop and implement a formal review and approval process related to drawdowns. This should include the creation and maintaining of supporting documentation which demonstrates who performed the review and when it was performed. This could be done via sign-offs, checklists, or electronic approvals.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 Federal Award Identification Number: H8000517; H8NCS54087 Award Periods: July 1, 2024 – February 28, 2025; March 1, 2025 – June 30, 2025 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Clinic was unable to provide documentation that a formal review and approval process had occurred prior to initiating drawdowns via the payment management system. Questioned Costs: None Context: This condition was identified during the review and testing of drawdowns as part of testing cash management. Cause: The Clinic has a limited number of resources in its finance department and as a result has incorporated the executive director into the review process. However, documentation was not created and maintained to shown that a formal review and approval had occurred prior to initiation drawdowns. Effect: The lack of documented review increases the risk that noncompliance with federal requirements could occur and not be prevented or detected in a timely manner. Repeat Finding: No. Recommendation: We recommend the Clinic develop and implement a formal review and approval process related to drawdowns. This should include the creation and maintaining of supporting documentation which demonstrates who performed the review and when it was performed. This could be done via sign-offs, checklists, or electronic approvals.
Allowable Activities and Costs, Cash Management, and Reporting Health Center Cluster – Assistance Listing No. 93.224 Recommendation: We recommend the Clinic develop and implement formal policies and procedures to ensure consistent review and approval over all applicable compliance requirements for federal programs. This should include but not limited to assigning responsibility for each compliance area, implementing documented review and approval controls (e.g., review of financial reports, cash drawdowns, and grant expenditures), and retaining evidence of review (e.g., sign-offs, checklists, or electronic approvals). Action taken in response to finding: The Clinic has implemented policies and procedures to ensure formal review and approval is documented for each compliance area. Name(s) of the contact person(s) responsible for corrective action: Kim Wieloch, Finance Director Planned completion date for corrective action plan: April 1, 2026.
FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
The Clinic’s sliding fee scale policy provides for the application of discounts to eligible patients based on the ability to pay. The Clinic has designed an internal control to provide a review and approval of eligibility determinations within the established sliding fee scale based on income and family size. During our testing of participants, it was noted that one out of the 40 individuals sampled and tested was billed incorrectly. The individual was billed more than they should have been based on the determined sliding fee scale level. Criteria: 42 CFR Sections 51c.303(e), (f), and (g) require a health center to apply sliding fee discounts to patients consistent with its sliding fee discount schedule. The Uniform Guidance requires grantees to design and implement internal controls over compliance to prevent, or detect and correct noncompliance with compliance requirements. Cause: The Clinic’s billing review process did not appropriately detect the billing error in assigning the sliding fee scale discount for the individual. Effect: The internal control did not operate effectively, and that failure resulted in an individual being billed incorrectly. Recommendation: Wipfli LLP recommends the Clinic to review its internal process for reviewing and approving bills before they are sent to patients. Views of responsible officials: We agree with the finding and have had already implemented corrective action during the current fiscal year.
Show full finding ▾Hide full finding ▴Finding No. 2024-001: Special Tests and Provision - Sliding Fee Scale Discounts Program Affected: Direct Award - Department of Health and Human Services: Health Center Program Cluster (Health Center Program AL No. 93.224). Grant No. H80CS00517, with grant periods July 1, 2023 through February 28, 2024, and March 1, 2024 through June 30, 2024. Questioned Costs: None Condition: The Clinic’s sliding fee scale policy provides for the application of discounts to eligible patients based on the ability to pay. The Clinic has designed an internal control to provide a review and approval of eligibility determinations within the established sliding fee scale based on income and family size. During our testing of participants, it was noted that one out of the 40 individuals sampled and tested was billed incorrectly. The individual was billed more than they should have been based on the determined sliding fee scale level. Criteria: 42 CFR Sections 51c.303(e), (f), and (g) require a health center to apply sliding fee discounts to patients consistent with its sliding fee discount schedule. The Uniform Guidance requires grantees to design and implement internal controls over compliance to prevent, or detect and correct noncompliance with compliance requirements. Cause: The Clinic’s billing review process did not appropriately detect the billing error in assigning the sliding fee scale discount for the individual. Effect: The internal control did not operate effectively, and that failure resulted in an individual being billed incorrectly. Recommendation: Wipfli LLP recommends the Clinic to review its internal process for reviewing and approving bills before they are sent to patients. Views of responsible officials: We agree with the finding and have had already implemented corrective action during the current fiscal year.
We have determined that the sliding fee set up in our EHR will miscalculate a patient’s sliding fee discount when a combination of particular conditions are met. A representative of the EHR company has confirmed that the system “does not behave as it should” when these circumstances occur. While it is rare that a slide patient would meet all of these conditions, it does happen from time to time. Because of this, we have begun verifying the discounts applied to every slide patient’s account to ensure accuracy. Additionally, we are restructuring the sliding fee discount program and will rebuild it within the EHR to remove the possibility of one of the conditions occurring, which should prevent the system from ever miscalculating the discount to be applied. Person(s) Responsible: Kim Wieloch, Finance Director Timing for Implementation: Verifying all SFS discounts: Currently in process and ongoing; Rebuilding SFS calculation structure in EHR: By 7/1/2025
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
FAC accepted this audit on February 15, 2023 — management decision was due August 15, 2023.
FAC accepted this audit on March 28, 2022 — management decision was due September 28, 2022.
FAC accepted this audit on October 11, 2021 — management decision was due April 11, 2022.
FAC accepted this audit on January 6, 2020 — management decision was due July 6, 2020.
FAC accepted this audit on January 21, 2019 — management decision was due July 21, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on April 3, 2018 — management decision was due October 3, 2018.
FAC accepted this audit on March 23, 2017 — management decision was due September 23, 2017.
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