The Community Clinic, Inc. d/b/a CCI Health ServicesNon-Profit

Health Center Program Cluster – ALN Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS10591 Program Year 17 and 18 Family Planning Services – ALN No. 93.217 U.S. Department of Health and Human Services Award No. FPHPA006584 Program Year 3 and 4 Criteria or Specific Requirement – Reporting – 45 CFR 75.342 Condition – The Organization is required to prepare and submit an annual Uniform Data System (UDS) for each calendar year and an annual Federal Financial Report (FFR) for each grant year for the Health Center Program Cluster and to prepare and submit quarterly Federal Cash Transaction Reports (FCTR) for each grant budget period for the Family Planning Services awards. These reports are to be prepared using accurate financial information. Cause – The Organization was unable to provide supporting documentation that agreed to the line items tested on the report. Effect or potential effect– Potential errors were made on the annual UDS report and Family Planning Services FFR reports. Questioned cost – None Context – The annual UDS and FFR reports for the Health Center Program Cluster and four quarterly FCTR reports for the Family Planning Services awards were selected for testing. The sampling methodology used is not and is not intended to be statistically valid. Of the ten inputs tested, two exceptions were noted related to the annual UDS report. Of the four reports, three reports including exceptions were noted in the quarterly Family Planning services reports. Identification as a Repeat Finding – Yes, findings 2024-002 and 2023-009. Recommendation – The Organization should revise policies and procedures over federal reporting to ensure reports are prepared using accurate information and supporting documentation for federal grant reports should be maintained. Views of Responsible Officials and Planned Corrective Actions – CCI Health Services will strengthen its processes to ensure all UDS, FFR, and FCTR reports are prepared using accurate financial information supported by appropriate documentation. A standardized federal reporting checklist is being developed to identify required data sources, outline reconciliation steps, and document preparer and reviewer responsibilities. All reports will be reconciled to the system reports and reviewed by both the Controller and CFO before submission to ensure accuracy and completeness. Supporting documentation for all federal reports will be maintained in a centralized location to ensure consistency and future audit readiness. Anticipated Completion/Implementation Date: End of Fiscal Year 2025

Health Center Program Cluster – ALN Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS10591 Program Years 17 and 18 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization's policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned cost – None Context – A sample of 40 encounters were tested out of the total population of 131,107 encounters. The sampling methodology used is not and is not intended to be statistically valid. Twenty patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their family size and household income documentation. Identification as a repeat finding, if applicable – Yes, finding 2024-003. Recommendation – We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions – CCI is implementing a system update within eCW to ensure the sliding fee schedule is accurately configured and consistently applied across all service locations. As part of this corrective action, CCI is developing a formal training program to ensure that all applicable employees understand the sliding fee requirements and possess the necessary knowledge to follow the established procedures. CCI is also establishing an internal review process to monitor compliance with the sliding fee policy. This process will include periodic sampling and review of sliding fee scale assessments to verify that eligibility determinations and discounts are being applied correctly and in accordance with policy. Any identified discrepancies will be addressed through targeted staff retraining or process adjustments, as appropriate. These corrective actions are designed to strengthen internal controls, ensure consistent application of the sliding fee program, and maintain compliance with regulatory and organizational requirements. Anticipated Completion/Implementation Date: End of Fiscal Year 2026

Health Center Program Cluster – ALN Nos. 93.224 and 93.527U.S. Department of Health and Human Services Award No. H80CS10591Program Year 16 and 17 Family Planning Services – ALN No. 93.217 U.S. Department of Health and Human Services Award No. FPHPA006584 Program Year 2 and 3 Criteria or Specific Requirement – Reporting – 45 CFR 75.342 Condition – The Organization is required to prepare and submit an annual Uniform Data System (UDS) for each calendar year and an annual Federal Financial Report (FFR) for each grant year for the Health Center Program Cluster and to prepare and submit quarterly Federal Cash Transaction Reports (FCTR) for each grant budget period for the Family Planning Services awards. These reports are to be prepared using accurate financial information. Cause – The Organization was unable to provide supporting documentation that agreed to the line items tested on the report. Effect or potential effect– Potential errors were made on the annual UDS report and Family Planning Services FFR reports. Questioned cost – None Context – The annual UDS and FFR reports for the Health Center Program Cluster and two quarterly FCTR reports for the Family Planning Services awards were selected for testing. The sampling methodology used is not and is not intended to be statistically valid. Of the ten inputs tested, six exceptions were noted related to the annual UDS report. Of the eight inputs tested, four exceptions were noted in the quarterly Family Planning services reports. Identification as a Repeat Finding – Yes, finding 2023-009. Recommendation – The Organization should revise policies and procedures over federal reporting to ensure reports are prepared using accurate information and supporting documentation for federal grant reports should be maintained. Views of Responsible Officials and Planned Corrective Actions – In September 2024, CCI Health Services appointed a new Chief Financial Officer (CFO) and expanded its accounting team, bringing in professionals with expertise in non-profit, grant, and healthcare financial management. CCI has implemented a tiered review system for reporting to ensure that reports are reviewed by individuals with knowledge of the reporting requirements prior to submission. Anticipated Completion/Implementation Date: End of Fiscal Year 2025

Health Center Program Cluster – ALN Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS10591 Program Years 16 and 17 Criteria or Specific Requirement – Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR sections 51c.303(g); and 42 CFR sections 56.303 (f)) Condition – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization's policy. Cause – The Organization did not comply with their sliding fee policy. Effect or potential effect – Sliding fee discounts were given to patients that were inconsistent with the Organization’s sliding fee discount policy. Questioned cost – None Context – A sample of 25 encounters were tested out of the total population of 119,773 encounters. The sampling methodology used is not and is not intended to be statistically valid. Three patients received a sliding fee adjustment that was inconsistent with the approved policy for the proper sliding fee adjustments based on their income documentation. Identification as a repeat finding, if applicable - Is not a repeat finding. Recommendation – We recommend management continue to ensure all personnel understand the sliding fee scale policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that eligible patients receive discounts in accordance with the sliding fee scale and the Health Center Program Compliance Manual. Views of Responsible Officials and Planned Corrective Actions – CCI is developing a training program for employees to support their understanding of the sliding fee scale policy and to ensure they have the knowledge to adhere to the requirements and guidelines set forth in the policy. CCI will review a sample of sliding fee scale assessments to ensure the policy is being applied correctly. Anticipated Completion/Implementation Date: End of Fiscal Year 2025

Finding No. 2023-004: Lack of Documentation of Management Review over Salary Certifications – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Teaching Health Center Graduate Medical Equipment Payment, ALN 93.530; Family Planning – Services, ALN 93.217; Refugee and Entrant Assistance – State – Administered Programs, ALN 93.566 U.S. Department of Agriculture: WIC Special Supplemental Nutrition Program for Women, Infants and Children, ALN 10.557 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within CCI, as well as within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding Yes Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charged to federal awards, noting any changes that need to be made. We also recommend that after this meeting, any amendments made to allocations, or decisions that no changes are necessary, be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2023-005: Inadequate System to Ensure Timely Filing and Review of Required Reports – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Grants for Capital Development in Health Centers, ALN 93.526; Teaching Health Center Graduate Medical Equipment Payment, ALN 93.530; Family Planning – Services, ALN 93.217; Refugee and Entrant Assistance – State – Administered Programs, ALN 93.566 U.S. Department of Agriculture: WIC Special Supplemental Nutrition Program for Women, Infants and Children, ALN 10.557 Criteria Pursuant to the terms of the grant agreement for ALN 93.217, federal financial reports are required to be submitted within 30 days after the end of each quarter. Also, the final report is required to be filed within 90 days of the end of the reporting period. Additionally, in accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition The quarterly federal financial report (Form 425) for ALN 93.217 for the period July 1 through September 30, 2022, was not submitted to HHS by the required due date. Also, there was no evidence of management review prior to submission. In addition, the Data Collection Form for the year ended June 30, 2023, was not submitted to the Federal Audit Clearinghouse by the due date, which is a finding for all federal awards. Context The quarterly Form 425 was due to HHS October 30, 2022, but was submitted on October 31, 2022. We noted that there was no evidence of review or approval of the financial report being submitted for reimbursement. In terms of the Data Collection Form for the year ended June 30, 2023, this report has not been submitted yet. This report was due on March 31, 2024. Cause Staff turnover in the Finance Department coupled with inadequate controls to ensure that general ledger accounts are reconciled properly and in a timely manner throughout the year. Effect Management is not in compliance with the requirement of the grant agreement and the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that management implement procedures to ensure that all federal reports are filed by the required due date. We also recommend that management implement a process of formal documentation for the review and approval of reports prior to submission. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2023-006: Noncompliance with Procurement Policy – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Grants for Capital Development in Health Centers, ALN 93.526 U.S. Department of Agriculture: WIC Special Supplemental Nutrition Program for Women, Infants and Children, ALN 10.557 Condition There is no formal documentation or evidence to support that a competitive price analysis for vendors selected by CCI or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected one sample for ALN 93.526, which was deemed sole sourced by management and noted that no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussion with management, we understand there was a bid and a contract put into place as of November 2023 which is after the year ended June 30, 2023, although the vendor was used for services prior to June 30, 2023. We selected five samples for ALN 10.557 which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause Controls were not in place to ensure that CCI’s procurement practices were in line with the Uniform Guidance and its internal Purchasing and Procurement Policy. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that a review of all vendor contract files used in federal awards be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. We also recommend that controls be established to ensure that CCI’s Purchasing and Procurement Policy is being followed. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2023-007: Noncompliance with Real Property and Equipment Requirements – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Grants for Capital Development in Health Centers, ALN 93.526; Criteria Under the Uniform Guidance, equipment and real property management requirements for cost-reimbursement contracts are contained in Section 200.313 (equipment), Section 200.311 (real property), and Section 52.245-1 (equipment and real property). According to these sections, the non-federal entity is required to maintain proper records for property and adequately safeguards and maintains property. Condition and Context CCI was awarded grant funding for the capital development of one of its health centers. During the year ended June 30, 2023, CCI used $850,083 of federal funds in connection with this initiative. While construction progressed during the year ended June 30, 2023, an insurance policy was not acquired on the property until December 2023. Cause Lack of management oversight over the compliance requirements specified in the Uniform Guidance which required all property acquired with federal funds be properly and adequately safeguarded from loss. Effect CCI was not in compliance with the provisions of the Uniform Guidance. Questioned Costs None. Repeat Finding No. Recommendation We recommend that management thoroughly review all federal and non-federal awards and prepare a spreadsheet which documents the significant terms of each award, including the award period, assistance listing number, cost-sharing requirements, special provisions as well as review the Uniform Guidance Compliance Supplement for additional requirements that may be applicable. This spreadsheet should be used by staff and reviewed by management to ensure that all provisions of the award and the Uniform Guidance are adhered to. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2023-008: Inadequate Account Reconciliations, Financial Close Process and Lack of Management Review – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Grants for Capital Development in Health Centers, ALN 93.526; Teaching Health Center Graduate Medical Equipment Payment, ALN 93.530; Family Planning – Services, ALN 93.217; Refugee and Entrant Assistance – State – Administered Programs, ALN 93.566 U.S. Department of Agriculture: WIC Special Supplemental Nutrition Program for Women, Infants and Children, ALN 10.557 Finding No. 2023-001 is also a finding under the Uniform Guidance. Criteria Good financial management requires that all accounts in the consolidated financial statements be reconciled and reviewed on a monthly basis and at year end. Condition and Context Reconciliations of certain general accounts, such as federal grant revenue and expenses did not begin until after the fiscal year ended, as the staff began to prepare for the annual audit. We also noted that such reconciliations were not thoroughly reviewed by management and there was a lack of documented evidence of such reviews. Additionally, management was unable to provide supporting evidence of proper review and approval over various expenses charged to federal awards. Cause Significant staff turnover in the Finance Department. Effect Financial reports prepared and reviewed by the Board and management and submitted to federal agencies during the year were likely inaccurate and delayed. The delays in the reconciliation of accounts also caused extensive delays during the audit process and affected CCI’s ability to fulfill financial reporting requirements to third-party stakeholders. Repeat Finding No. Recommendation We recommend that all general ledger accounts be reconciled on a monthly basis. A monthly and year-end financial close checklist should be utilized to identify and track all general ledger account reconciliations. This will reduce the occurrence of unreconciled accounts and activity that may result in material misstatements of the consolidated financial statements and amounts reported on federal reports required to be filed. This checklist should include all accounts that must be reconciled, as well as document other procedures that should be performed, the frequency of occurrence, responsible person and the date each item is to be completed. Upon completion of the task, the checklist should be initialed and dated by the employee who completed the task. The completed checklist should also be reviewed, initialed and dated by a management-level employee to document satisfactory completion of all reconciliations and financial close procedures. We also recommend that management perform thorough and timely review of work prepared or performed by the Finance Department staff for accuracy and completeness. We also recommend that CCI implement procedures to ensure that all expenses charged to federal awards are reviewed and approved and that such review is documented. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2023-009: Non-Compliance over Reporting and Tracking of Non-Federal Share – Material Weakness in Internal Control Over Compliance U.S. Department of Health and Human Services: Family Planning - Services, ALN 93.217 Criteria Reports required to be filed under Uniform Guidance and the grant award must be completed accurately. Condition and Context According to the Notice of Award, CCI was awarded $1,450,000 under the federal award, with a requirement of the Organization to provide cost-sharing of $1,963,236, for a total approved budget of $3,413,236 over the award budget period of April 1, 2022 – March 31, 2023. Our review of the Federal Financial Report (SF 425) filed during the year revealed that the Condition and Context (continued) recipient share (the cost share) of the project was not reported. Although no such amount was reported, CCI was able to provide supporting documentation of $1,692,671 of costs incurred in the program, leaving a remaining balance of $1,720,565 in unsupported costs. While CCI was able to provide supporting documentation of total program income of $2,227,577 for the period, which was also used in the program, there is no evidence that the remaining $1,185,659 non-federal share requirement was met. Cause Management was not aware of the non-federal share requirement and the need to report such information on reports. Management also asserts that additional indirect and overhead costs were incurred, but were not tracked in the general ledger. Effect Financial reports submitted were incomplete and inaccurate. Questioned Costs $1,185,659 Repeat Finding No. Recommendation We recommend that management review the terms and conditions of all federal awards and ensure that procedures and systems are in place to ensure that all information required to be reported on federal financial reports is properly tracked and reported. We recommend that these procedures and tracking be reviewed by a management level employee to ensure compliance with federal laws and regulations. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within the organization within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. We also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

U.S. Department of Health and Human Services (HHS), Family Planning Services, ALN 93.217 Criteria The HHS grant agreement requires that federal financial reports be submitted within 30 days after the end of each quarter. Also, the final report is required to be filed within 90 days of the end of the reporting period. Additionally, in accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditor?s report or nine months after the end of the fiscal year, whichever comes first. Condition The final federal financial report (Form 425) for the period January 1, 2022 through March 31, 2022 and the quarterly report for period June 1, 2021 through September 30, 2021 were not submitted to HHS by the required due dates. In addition, the Data Collection Form for the year ended June 30, 2022, was not submitted to Federal Audit Clearinghouse by the due date. Context The final form 425 was due to HHS June 30, 2022, but was submitted on September 15, 2022. The quarterly report was due to HHS October 30, 2021, but was submitted on November 1, 2021. In terms of the Data Collection Form for the year ended June 30, 2022, this report has not been submitted yet. This report was due on March 31, 2023. Cause Staff turnover in the finance department and insufficient tracking system to ensure deadlines are met. Effect Management is not in compliance with the requirement of the grant agreement and OMB Uniform Guidance. Questioned Costs None Repeat Finding No. Recommendation We recommend that management implement procedures to ensure that all federal reports are filed by the required due date. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Condition There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected two samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause CCI?s procurement policy was not updated to include the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2021-002: Salary Certifications ? Significant Deficiencies in Internal Control Over Financial Reporting Condition Salaries charged to the federal award were based on preliminary time and effort estimates that were periodically reviewed by program managers but were not ultimately certified by staff. Context Time charges to the federal award were based upon estimates established by CCI through the grant budgeting process. While time sheets were prepared by employees, such timesheets only reflected the employees? home office or department basically serving as evidence of attendance document and record. Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Cause CCI had been following a policy that had been implemented and utilized for several years. Effect The federal award may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management establish policies and procedures that are consistent with the Uniform Guidance administrative requirements with regards to compensation and allocable costs. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

Finding No. 2021-003: Procurement Policy ? Significant Deficiency in Internal Control Over Financial Reporting Condition There is no formal documentation or evidence to support that a competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected three samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause CCI?s procurement policy was not updated to include the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding No. Recommendation We recommend that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan

Finding No. 2021-004: Cut Off Procedures ? Significant Deficiency in Internal Control Over Financial Reporting Condition A certain expense was not recognized in the proper accounting period. Context We noted an instance whereby an expense for fiscal year 2022 services was recorded and reported as expense during fiscal year 2021. Criteria Uniform Guidance requires CCI to adhere to established accounting policies. CCI?s policy requires expenditures reported on the SEFA to be reported on the accrual basis of accounting. Cause Expenses were recorded based on when the invoice was paid. Effect Expenses were overstated by $5,600 for the year then ended June 30, 2021. Questioned Costs None, as although the expense was charged in the incorrect period, it was a valid expense. Repeat Finding No. Recommendation We recommend that the CCI reinforce its controls to ensure that expenses are recorded as goods and services are received instead of when invoices are paid. Views of Responsible Officials and Planned Corrective Action See corrective action plan.

2019-003 Ineligible Sliding Fee Patient Criteria: In accordance with the Code of Federal Regulations section 51c.303(f), no discount should be applied for health center services to individuals or families with annual income above 200 percent of the Federal Poverty Guidelines. The internal controls pertaining to the eligibility of sliding fee patients should include procedures that ensure that the patient?s income levels are within the designated fee scale and are below 200% of the federal poverty level. Condition: CCI provided a sliding fee discount to a patient with an income level above the defined limit for their income level and family size. Cause: The individual who processed the patient?s sliding fee application did not adequately recognize that the patient?s income level was above the program?s threshold. Additionally, this was not discovered in subsequent reviews by management. Effect: In regard to the factual error identified, CCI provided a sliding fee discount of $183 to a patient who was not eligible for the federal program. This error was identified for one patient within the sample of 40 patients selected for testing. When this error was projected across the remaining sliding fee adjustment population, the total potential projected error was $89,900. Questioned Costs: $183 Recommendation: We recommend that CCI implement controls that provide for a thorough review by management for all sliding fee patient applications and ensures that patients are eligible and within the correct level.