EIN: 481151382
UEI: PKRMQZBZPZD1
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 11, 2022. 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 March 11, 2023 (1265 days ago).
What is a management decision? →Sliding fee discount was improperly calculated for two eligible patients. Cause: Sliding fee discount policy was not followed. Effect: Control procedures did not prevent the incorrect sliding fee discount being applied to the patient account. Perspective Information: Two instances were noted in which the sliding fee discount applied to an eligible patient account was improperly calculated. The total sample size was 60. The sampling was a statistically valid sample. Repeat Finding: Repeat finding of 2020-003. Recommendations: Add to control procedures an approval process for the sliding fee discount to be applied to a patient account that would include a business office manager and/or supervisor approving the discount that is applied to the account. As part of the approval process recommend that they verify eligibility for receiving the discount, including that appropriate documentation was received and recalculation of the approved discount. Views of Responsible Officials: Near the end of 2021, Vibrant Health strengthened its procedures by adding controls to increase oversight of sliding fee discounts being added to patient accounts. In addition, Vibrant Health has increased internal audit functions to evaluate progress and opportunities for further education and training.
Show full finding ▾Hide full finding ▴Identification: 93.224 and 93.527 United States Department of Health and Human Services, Health Center Cluster, Multiple federal award numbers; Significant Deficiency over compliance; Special Tests and Provisions requirement. Criteria: Health centers must prepare and apply a sliding fee discount schedule so that amounts owed for health center services by eligible patients are adjusted based on the patient's ability to pay. Condition: Sliding fee discount was improperly calculated for two eligible patients. Cause: Sliding fee discount policy was not followed. Effect: Control procedures did not prevent the incorrect sliding fee discount being applied to the patient account. Perspective Information: Two instances were noted in which the sliding fee discount applied to an eligible patient account was improperly calculated. The total sample size was 60. The sampling was a statistically valid sample. Repeat Finding: Repeat finding of 2020-003. Recommendations: Add to control procedures an approval process for the sliding fee discount to be applied to a patient account that would include a business office manager and/or supervisor approving the discount that is applied to the account. As part of the approval process recommend that they verify eligibility for receiving the discount, including that appropriate documentation was received and recalculation of the approved discount. Views of Responsible Officials: Near the end of 2021, Vibrant Health strengthened its procedures by adding controls to increase oversight of sliding fee discounts being added to patient accounts. In addition, Vibrant Health has increased internal audit functions to evaluate progress and opportunities for further education and training.
Corrective Action Plan: Near the end of 2021, Vibrant Health strengthened its procedures by adding controls to increase oversight of sliding fee discounts being added to patient accounts. In addition, Vibrant Health has increased internal audit functions to evaluate progress and opportunities for further education and training. Anticipated Completion Date: Currently Implemented.
2020-003
FAC accepted this audit on December 2, 2021 — management decision was due June 2, 2022.
Federal expenditures were paid after the draw down request for reimbursement of the expenditure was submitted. Cause: The draw down spreadsheets used to track federal expenditures that are submitted for reimbursement contain the expenditure and the period the expenditure applies to but does not include the date the expenditure was paid. Effect: Control procedures need to be strengthened to prevent noncompliance. Perspective Information: Nine instances were noted from a sample of 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add a paid date of the expenditure to the draw down spreadsheet that is used to track federal expenditures that are submitted for reimbursement.
Show full finding ▾Hide full finding ▴Identification: 93.224 and 93.527 United States Department of Health and Human Services, Health Center Cluster, Federal award numbers: H8DCS36159-01-01 (COVID-19 Health Center CARES Act funding), H8CCS34806-01-01 (COVID-19 HRSA FY 2020 Coronavirus Supplemental Funding), H80CS33652-02-01 (HRSA HHS 330 Health Center Program Award FY 2021) Criteria: 2 CFR section 200.305(b)(3) Condition: Federal expenditures were paid after the draw down request for reimbursement of the expenditure was submitted. Cause: The draw down spreadsheets used to track federal expenditures that are submitted for reimbursement contain the expenditure and the period the expenditure applies to but does not include the date the expenditure was paid. Effect: Control procedures need to be strengthened to prevent noncompliance. Perspective Information: Nine instances were noted from a sample of 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add a paid date of the expenditure to the draw down spreadsheet that is used to track federal expenditures that are submitted for reimbursement.
Currently, a spreadsheet tracking tool is utilized to support the drawdown of federal funds. A paid column will be added to the spreadsheet to help ensure drawdowns of federal funds do not occur until after supporting expenses have also been paid.
Documentation not available to verify that federal expenditures are not being purchased for vendors that have been suspended or debarred. Cause: Controls are not in place to determine if contracts are being entered into with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Effect: Control procedures need to be strengthened to prevent noncompliance. Perspective Information: Applies to all federal expenditures for the period under audit that are subject to the procurement standards. No noncompliance was noted in the sample of 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add control procedures that include verification of vendor not being on the suspension and debarment listing.
Show full finding ▾Hide full finding ▴Identification: 93.224 and 93.527 United States Department of Health and Human Services, Health Center Cluster, Federal award numbers: H80C33652-01 (HRSA HHS 330 Health Center Program Award FY 2020), H8DCS36159-01-01 (COVID-19 Health Center CARES Act funding), H8CCS34806-01-01 (COVID-19 HRSA FY 2020 Coronavirus Supplemental Funding), H80CS33652-02-01 (HRSA HHS 330 Health Center Program Award FY 2021), H8ECS37840-01 (COVID-19 FY 2020 Expanding Capacity for Coronavirus Testing) Criteria: 2 CFR section 200.214 Condition: Documentation not available to verify that federal expenditures are not being purchased for vendors that have been suspended or debarred. Cause: Controls are not in place to determine if contracts are being entered into with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Effect: Control procedures need to be strengthened to prevent noncompliance. Perspective Information: Applies to all federal expenditures for the period under audit that are subject to the procurement standards. No noncompliance was noted in the sample of 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add control procedures that include verification of vendor not being on the suspension and debarment listing.
In an effort to enhance controls around the addition of vendors, specific procedures will be formalized requiring that vendors are checked against the suspension and debarment listing.
Sliding fee discount was given to patients without determining eligibility and improper discount was given to eligible patients. Cause: Sliding fee discount policy was not followed. Effect: Control procedures did not prevent sliding fee discount policy from being applied prior to determining eligibility or preventing miscalculation of sliding fee discount to apply to patient account. Perspective Information: Two instances were noted in which the sliding fee discount was applied to patient accounts without verification of eligibility. Three instances were noted in which the sliding fee discount applied to an eligible patient account was improperly calculated. The total sample size was 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add to control procedures an approval process for the sliding fee discount to be applied to a patient account that would include a business office manager and/or supervisor approving the discount that is applied to the account. As part of the approval process recommend that they verify eligibility for receiving the discount, including that appropriate documentation was received and recalculation of the approved discount.
Show full finding ▾Hide full finding ▴Identification: 93.224 and 93.527 United States Department of Health and Human Services, Health Center Cluster, Federal award numbers: H80C33652-01 (HRSA HHS 330 Health Center Program Award FY 2020), H8DCS36159-01-01 (COVID-19 Health Center CARES Act funding), H8CCS34806-01-01 (COVID-19 HRSA FY 2020 Coronavirus Supplemental Funding), H80CS33652-02-01 (HRSA HHS 330 Health Center Program Award FY 2021), H8ECS37840-01 (COVID-19 FY 2020 Expanding Capacity for Coronavirus Testing) Criteria: Health centers must prepare and apply a sliding fee discount schedule so that amounts owed for health center services by eligible patients are adjusted based on the patient?s ability to pay. Condition: Sliding fee discount was given to patients without determining eligibility and improper discount was given to eligible patients. Cause: Sliding fee discount policy was not followed. Effect: Control procedures did not prevent sliding fee discount policy from being applied prior to determining eligibility or preventing miscalculation of sliding fee discount to apply to patient account. Perspective Information: Two instances were noted in which the sliding fee discount was applied to patient accounts without verification of eligibility. Three instances were noted in which the sliding fee discount applied to an eligible patient account was improperly calculated. The total sample size was 60. The sampling was a statistically valid sample. Repeat Finding: N/A Recommendations: Add to control procedures an approval process for the sliding fee discount to be applied to a patient account that would include a business office manager and/or supervisor approving the discount that is applied to the account. As part of the approval process recommend that they verify eligibility for receiving the discount, including that appropriate documentation was received and recalculation of the approved discount.
Vibrant Health will add controls and procedures to increase oversight of sliding fee discounts being added to patient accounts. Vibrant Health will also increase internal audit functions to evaluate progress and opportunities for further education and training.
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