Island Health, Inc.

Finding 2022.003: Allowable Costs/Activities Allowed or Unallowed - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria In accordance with 2 CFR, Part 200.430I(i)(1), charges to Federal Awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.40.3(g). Condition Charges to Federal Awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by proper approval. Cause The Center's internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center's internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect or Potential Effect Failure to ensure accurate wage and allocation of employees' time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program for testing. Out of the 25 transactions tested, we noted 16 instances where there was no formal approval of payrates and where they were not appropriately reflected in the payroll registers; 23 instances where timecards were not appropriately reflected in the payroll registers; and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 13 transactions tested, we noted 6 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Yes, see finding 2021-003. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently reinforces its internal controls over nonpayroll expenditures to ensure all expenditures were approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review.

Finding 2022.004: Reporting - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria In accordance with §200.328, Financial Reporting, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House within the earlier of 30 days after the receipt of the audit report or nine months after the end of the audit period. In addition, in accordance with grant requirements, annual Federal Financial Reports ("FFR") must be submitted no later than indicated in the notice of grant award. Condition For the year ended June 30, 2022, the Center did not submit their annual audit in accordance with the Uniform Guidance on a timely basis. In addition, the Center submitted the annual FFR late for the budget period ended March 31, 2022. Cause Due to the turnover in the financial leadership, the ongoing pandemic and the closing of their prior audit firm, these reports were not submitted on time. Effect or Potential Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance and with DHHS grant requirements. Questioned Costs None. Identification of Repeat Finding Yes, see finding 2021-004. Recommendation The Center should establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that the financial statement audit is submitted on a timely basis to the Federal government. The Center should also ensure that all reporting requirements are monitored and met on a timely basis. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all reports are submitted timely in accordance with the Uniform Guidance and DHHS grant requirements.

Finding 2022.005: Procurement, Suspension and Debarment - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors for any suspensions or debarment. Effect or Potential Effect The Center may procure goods and services from vendors that have been suspended or debarred from doing business with the federal government. Questioned Costs None. Context We selected a sample of 4 vendors for suspension and debarment for testing. For 3 of the 4 vendors tested, management did not provide adequate supporting documentation for the review and approval of each vendor as to whether they have been suspended or debarred. Identification of Repeat Finding Yes, see finding 2021-005. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Finding 2022.006: Cash Management - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria In accordance with §200.305, Federal Payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect or Potential Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 9 drawdowns for testing of cash management. We noted there was no formal approval or evidence of review for all 9 drawdowns. Identification of Repeat Finding Yes, see finding 2021-006. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Finding 2022.007: Period of Performance - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2022 and 2023, H8DCS35487 - 2021, and H8F40829 - 2023 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance that were authorized by the federal awarding agency or pass-through entity (2 CFR sections, 200.308, 200.309 and 200.403(h)). Condition There was no evidence of the Center's review and approval of the period of performance for expenditures during the year. Cause The Center did not have adequate controls to review period of performance to ensure all goods and services are appropriately included or excluded. Effect or Potential Effect The Center may charge goods or services to the grant that are not within the grant's period of performance. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over period of performance. Out of the 25 transactions tested, we noted 25 instances where there was no formal approval of the cost charged to the major program by evidence of a review signature on the labor reports and 23 of the 25 transactions did not have approved timecards for the given periods. Additionally, we selected 13 nonpayroll transactions where 6 instances did not have evidence of review. Identification of Repeat Finding Yes, see finding 2021-007. Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of approval over the period of performance for goods and services purchased under the grant.

Finding 2021-003: Activities Allowed or Unallowed - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with 2 CFR, Part 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.40.3(g). Condition Charges to Federal Awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by proper approval. Cause The Center's internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center's internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee's time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program for testing. Out of the 25 transactions tested, we noted 21 instances where there was no formal approval of payrates and where they were not appropriately reflected in the payroll registers, 15 instances where timecards were not appropriately reflected in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of five transactions tested, we noted five instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Yes, see finding 2020-003. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently reinforces its internal controls over nonpayroll expenditures to ensure all expenditures were approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review.

Finding 2021-003: Activities Allowed or Unallowed - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with 2 CFR, Part 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.40.3(g). Condition Charges to Federal Awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by proper approval. Cause The Center's internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center's internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee's time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program for testing. Out of the 25 transactions tested, we noted 21 instances where there was no formal approval of payrates and where they were not appropriately reflected in the payroll registers, 15 instances where timecards were not appropriately reflected in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of five transactions tested, we noted five instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Yes, see finding 2020-003. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently reinforces its internal controls over nonpayroll expenditures to ensure all expenditures were approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review.

Finding 2021-004: Reporting - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.328, Financial Reporting, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House within the earlier of 30 days after the receipt of the audit report or nine months after the end of the audit period. In addition, in accordance with grant requirements, annual Federal Financial Reports ("FFR") must be submitted no later than indicated in the notice of grant award. Condition For the year ended June 30, 2021, the Center did not submit their annual audit in accordance with the Uniform Guidance on a timely basis. In addition, the Center submitted the annual FFR late for the budget period ended January 31, 2021. Cause Due to the turnover in the financial leadership, the ongoing pandemic and the closing of their prior audit firm, these reports were not submitted on time. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance and with DHHS grant requirements. Questioned Costs None. Identification of Repeat Finding Yes, see finding 2020-004. Recommendation The Center should establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that the financial statement audit is submitted on a timely basis to the Federal government. The Center should also ensure that all reporting requirements are monitored and met on a timely basis. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all reports are submitted timely in accordance with the Uniform Guidance and DHHS grant requirements.

Finding 2021-004: Reporting - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.328, Financial Reporting, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House within the earlier of 30 days after the receipt of the audit report or nine months after the end of the audit period. In addition, in accordance with grant requirements, annual Federal Financial Reports ("FFR") must be submitted no later than indicated in the notice of grant award. Condition For the year ended June 30, 2021, the Center did not submit their annual audit in accordance with the Uniform Guidance on a timely basis. In addition, the Center submitted the annual FFR late for the budget period ended January 31, 2021. Cause Due to the turnover in the financial leadership, the ongoing pandemic and the closing of their prior audit firm, these reports were not submitted on time. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance and with DHHS grant requirements. Questioned Costs None. Identification of Repeat Finding Yes, see finding 2020-004. Recommendation The Center should establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that the financial statement audit is submitted on a timely basis to the Federal government. The Center should also ensure that all reporting requirements are monitored and met on a timely basis. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all reports are submitted timely in accordance with the Uniform Guidance and DHHS grant requirements.

Finding 2021-005: Procurement, Suspension and Debarment - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors for any suspensions or debarment. Effect The Center may procure goods and services from vendors that have been suspended or debarred from doing business with the federal government. Questioned Costs None. Context We selected a sample of four vendors for suspension and debarment for testing. For all four vendors tested, management did not provide adequate supporting documentation for the review and approval of each vendor as to whether they have been suspended or debarred. Identification of Repeat Finding Yes, see finding 2020-005. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Finding 2021-005: Procurement, Suspension and Debarment - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors for any suspensions or debarment. Effect The Center may procure goods and services from vendors that have been suspended or debarred from doing business with the federal government. Questioned Costs None. Context We selected a sample of four vendors for suspension and debarment for testing. For all four vendors tested, management did not provide adequate supporting documentation for the review and approval of each vendor as to whether they have been suspended or debarred. Identification of Repeat Finding Yes, see finding 2020-005. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Finding 2021-006: Cash Management - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.305, Federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected seven drawdowns for testing of cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Yes, see finding 2020-006. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Finding 2021-006: Cash Management - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria In accordance with §200.305, Federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected seven drawdowns for testing of cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Yes, see finding 2020-006. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Finding 2021-007: Period of Performance - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance that were authorized by the federal awarding agency or pass-through entity (2 CFR sections, 200.308, 200.309 and 200.403(h)). Condition There was no evidence of the Center's review and approval of the period of performance for expenditures during the year. Cause The Center did not have adequate controls to review period of performance to ensure all goods and services are appropriately included or excluded. Effect The Center may charge goods or services to the grant that are not within the grant's period of performance. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over period of performance. Out of the 25 transactions tested, we noted 25 instances where there was no formal approval of the cost charged to the major program by evidence of a review signature on the labor reports. Additionally, we selected five nonpayroll transactions where all five instances did not have evidence of review. Identification of Repeat Finding Yes, see finding 2020-007. Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of approval over the period of performance for goods and services purchased under the grant.

Finding 2021-007: Period of Performance - Material Weakness Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021, H8DCS35487 - 2020, H8CCS34364 - 2020, H8ECS38373 - 2020, and H8F40829 - 2021 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance that were authorized by the federal awarding agency or pass-through entity (2 CFR sections, 200.308, 200.309 and 200.403(h)). Condition There was no evidence of the Center's review and approval of the period of performance for expenditures during the year. Cause The Center did not have adequate controls to review period of performance to ensure all goods and services are appropriately included or excluded. Effect The Center may charge goods or services to the grant that are not within the grant's period of performance. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over period of performance. Out of the 25 transactions tested, we noted 25 instances where there was no formal approval of the cost charged to the major program by evidence of a review signature on the labor reports. Additionally, we selected five nonpayroll transactions where all five instances did not have evidence of review. Identification of Repeat Finding Yes, see finding 2020-007. Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of approval over the period of performance for goods and services purchased under the grant.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria According to 2 CFR, Part 200.430(i)(1) charges to Federal awards for salaries and wages must be based on records that accurately reflect the actual work performed, which must, among other things: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) and reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Additionally, costs must be adequately documented, as per 2 CFR 200.403(g). Condition Charges to Federal awards for salaries and wages were not supported by properly approved payrates, and timesheets did not agree to payroll registers. Additionally, nonpayroll expenditures were not supported by properly approval. Cause The Center’s internal controls over payroll were not consistently followed to ensure payrates were approved and timesheets agreed to payroll registers. Additionally, the Center’s internal controls over nonpayroll expenditures were not consistently followed to ensure that expenditures were approved. Effect Failure to ensure accurate wage and allocation of employee time across programs could result in non-compliance with the grant requirements or unallowable costs being charged. Additionally, failure to ensure accurate nonpayroll expenditures could result in a non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over allowable costs. Out of the 25 transactions tested, we noted 15 instances where there was no formal approval of payrates, 4 instances where timecards did not appropriately reflect in the payroll registers, and all 25 labor reports showed no formal approval documented. Additionally, for nonpayroll allowable costs, out of 3 transactions tested, we noted 3 instances where there was no formal approval showing review that the cost was allowable under the program. Identification of Repeat Finding Not a repeat finding. Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently enforce its internal controls over nonpayroll expenditures to ensure all expenditures are approved by the appropriate supervisor. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all expenditures have evidence of formal approval of review

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.328, Financial Reporting, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House within the earlier of 30 days after the receipt of the audit report or nine months after the end of the audit period. In addition, in accordance with grant requirements, annual Federal Financial Reports ("FFR") must be submitted no later than indicated in the notice of grant award. Condition For the year ended June 30, 2020, the Center did not submit their annual audit in accordance with the Uniform Guidance on a timely basis. In addition, the Center submitted the annual FFR late for the budget period ended January 31, 2020. Cause Due to the turnover in the financial leadership, the ongoing pandemic and the closing of their prior audit firm, these reports were not submitted on time. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance and with DHHS grant requirements. Questioned Costs None. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that that financial statement audit is submitted on a timely basis to the Federal government. The Center should also ensure that all reporting requirements are monitored and met on a timely basis. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all report are submitted timely in accordance with Uniform Guidance and DHHS grant requirements.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.328, Financial Reporting, annual audit reports of recipients of federal funds are required to be submitted to the Federal Audit Clearing House within the earlier of 30 days after the receipt of the audit report or nine months after the end of the audit period. In addition, in accordance with grant requirements, annual Federal Financial Reports ("FFR") must be submitted no later than indicated in the notice of grant award. Condition For the year ended June 30, 2020, the Center did not submit their annual audit in accordance with the Uniform Guidance on a timely basis. In addition, the Center submitted the annual FFR late for the budget period ended January 31, 2020. Cause Due to the turnover in the financial leadership, the ongoing pandemic and the closing of their prior audit firm, these reports were not submitted on time. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance and with DHHS grant requirements. Questioned Costs None. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should establish controls to ensure all accounting records are analyzed and proper support is available in order to ensure that that financial statement audit is submitted on a timely basis to the Federal government. The Center should also ensure that all reporting requirements are monitored and met on a timely basis. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure all report are submitted timely in accordance with Uniform Guidance and DHHS grant requirements.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors for suspension and debarment in accordance with Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors for any suspensions or debarment. Effect The Center may procure goods and services from vendors that have been suspended or debarred from doing business with the Federal government. Questioned Costs None. Context We selected a sample of 3 vendors for suspension and debarment for testing. For all 3 vendors tested, management did not provide adequate supporting documentation to support that the vendors were not suspended or debarred. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors for suspension and debarment in accordance with Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors for any suspensions or debarment. Effect The Center may procure goods and services from vendors that have been suspended or debarred from doing business with the Federal government. Questioned Costs None. Context We selected a sample of 3 vendors for suspension and debarment for testing. For all 3 vendors tested, management did not provide adequate supporting documentation to support that the vendors were not suspended or debarred. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309 and 200.403 (h)). Condition There was no evidence of the Center's review and approval of the period of performance for expenditures during the year. Cause The Center did not have adequate controls to review period of performance to ensure all goods and services are appropriately included or excluded. Effect The Center may charge goods or services to the grant that are not within the grant's period of performance. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over period of performance. Out of the 25 transactions tested, we noted 25 instances where there was no formal approval of the cost charged to the major program by evidence of a review signature on the labor reports. Additionally, we selected 3 nonpayroll transactions where all 3 instances did not have evidence of review. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of approval over the period of performance for goods and services purchased under the grant.

Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309 and 200.403 (h)). Condition There was no evidence of the Center's review and approval of the period of performance for expenditures during the year. Cause The Center did not have adequate controls to review period of performance to ensure all goods and services are appropriately included or excluded. Effect The Center may charge goods or services to the grant that are not within the grant's period of performance. Questioned Costs None. Context We selected 25 payroll transactions charged to the federal program to test controls over period of performance. Out of the 25 transactions tested, we noted 25 instances where there was no formal approval of the cost charged to the major program by evidence of a review signature on the labor reports. Additionally, we selected 3 nonpayroll transactions where all 3 instances did not have evidence of review. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of approval over the period of performance for goods and services purchased under the grant.