EIN: 521073362
UEI: CPKRFVZ98PH9
Audited by: Milligan and Company, LLC
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. 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 30, 2026 (158 days ago).
What is a management decision? →The Organization submitted the annual FFRs more than 90 days after the end of the budget period. Program income amount reported could not be substantiated. Criteria: The Organization, as a recipient of the Health Center Program Cluster funds, is required to submit annual Federal Financial Report (FFR) (SF-425) 90 days after the end of the budget period. Cause: The Organization has not enforced its written financial closing and reporting policies and procedures to ensure FFRs were submitted timely. Effect: The Organization did not comply with submitting FFRs by the due date and could not support the program income reported on the FFR. Context: We obtained and reviewed the completed annual FFRs and noted the reports were submitted 19 and 25 days later, respectively, for each of the grants after the due dates. Questions Costs: None Recommendation: We recommend management create a plan to ensure required program reports are completed by or before their due dates, to avoid punitive damages for noncompliance. Management should consider delegating the preparation to someone else other than the CFO and have the CFO instead review and submit. View of responsible officials and planned corrective actions:
Show full finding ▾Hide full finding ▴Finding 2024-003: Health Center Program Cluster U.S. Department of Health and Human Services – Assistance Listing No. 93.224/93.527; Grant No. H80CS24175 and H8L51564; Grant Periods: May 1, 2023 to April 30, 2025 and September 1, 2023 to December 31, 2024 Condition: The Organization submitted the annual FFRs more than 90 days after the end of the budget period. Program income amount reported could not be substantiated. Criteria: The Organization, as a recipient of the Health Center Program Cluster funds, is required to submit annual Federal Financial Report (FFR) (SF-425) 90 days after the end of the budget period. Cause: The Organization has not enforced its written financial closing and reporting policies and procedures to ensure FFRs were submitted timely. Effect: The Organization did not comply with submitting FFRs by the due date and could not support the program income reported on the FFR. Context: We obtained and reviewed the completed annual FFRs and noted the reports were submitted 19 and 25 days later, respectively, for each of the grants after the due dates. Questions Costs: None Recommendation: We recommend management create a plan to ensure required program reports are completed by or before their due dates, to avoid punitive damages for noncompliance. Management should consider delegating the preparation to someone else other than the CFO and have the CFO instead review and submit. View of responsible officials and planned corrective actions:
The task of completing program reports will be immediately assigned to the senior accountant. The senior accountant name and email address will be added to communications with the funder so that he receives notices. Once completed the senior accountant will provide to the CFO who will review and submit it.
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2022 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. The request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of the audit. Repeat Finding: Yes, 2021-001. Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy.View of responsible officials and planned corrective actions: FMCS concurs with the finding and recommendation of the auditor. The reason this is a repeat finding is because this finding occurred on the 2020 audit, which was completed February 1, 2022. (a three-year period). Our response to the finding was "The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022". The policy was revised and presented to and approved by the board of directors at the March 16, 2022, meeting. The training occurred for the human resources (HR) staff, who are charged with performing the compliance check, in March. The policy was implemented in March 2022.
Show full finding ▾Hide full finding ▴Finding 2022-002: Procurement Suspension and Debarment U.S. Department of Health and Human Services ? Assistance listing No. 93.526, Grants for Capital Development in Health Centers, award number C8ECS44745. Criteria: In accordance with 2 CFR section 200.214, Suspension and Debarment, ?The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Condition: FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2022 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. The request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of the audit. Repeat Finding: Yes, 2021-001. Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy.View of responsible officials and planned corrective actions: FMCS concurs with the finding and recommendation of the auditor. The reason this is a repeat finding is because this finding occurred on the 2020 audit, which was completed February 1, 2022. (a three-year period). Our response to the finding was "The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022". The policy was revised and presented to and approved by the board of directors at the March 16, 2022, meeting. The training occurred for the human resources (HR) staff, who are charged with performing the compliance check, in March. The policy was implemented in March 2022.
FMCS concurs with the finding. Part of the issue is related to staffing shortages, which increases the demands on the providers---resulting in staff burnout. We have already developed policies and procedures for locking notes as well as attempting to hire an auditor. In addition, we send out monthly reminders to lock notes. We have refrained from taking punitive actions for fear that the provider will leave and that our patients will be impacted. We will increase the frequency of the reminders to bi-monthly and continue our efforts to recruit an auditor.
2021-001
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2021 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. Our request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of our audit. Repeat Finding: Yes, 2020-002. Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services ? Assistance listing No. 93.224, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For The Homeless, And Public Housing Primary Care), award numbers H80CS24175, H8CCS34661, H8DCS35961, H8ECS38692, and H8FCS41735. Criteria: In accordance with 2 CFR section 200.214, Suspension and debarment, ?The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Condition: FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2021 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. Our request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of our audit. Repeat Finding: Yes, 2020-002. Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy.
FAMILY AND MEDICAL COUNSELING SERVICE, INC. CORRECTIVE ACTION PLAN Year Ended December 31, 2021 Name and Address of Independent Public Accounting Firm: Milligan and Company, LLC 105 North 22nd Street, Philadelphia, PA 19103 Audit Period: December 31, 2021 The findings from the December 31, 2021 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARDS PROGRAMS AUDITS Assistance Listing No. 93.224: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, And Public Housing Primary Care) 2021-001: Procurement Suspension and Debarment ? Significant deficiency Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with requirement. Corrective Action: FMCS concurs with the finding and recommendation of the auditor. This finding occurred on the 2020 audit, which was completed February 1, 2022. Our response to the finding was "The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022". The policy was revised and presented to and approved by the board of directors at the March 16, 2022 meeting. The training occurred for the HR staff, who are charged with performing the compliance check, in March. The policy was implemented in March 2022.
2020-002
FAC accepted this audit on January 31, 2022 — management decision was due July 31, 2022.
Although Medicaid wrap third-party payor accounts receivable balances were analyzed and adjusted prior to the start of the audit, subsequent receipts needed to be reviewed further to determine collectibility and reasonableness of the balance. A significant adjustment was made to the accounts receivable balance at the end of the audit, as a result of additional analysis. Effect: Periodic reporting may be inaccurate if analysis is not done timely. Cause: Medicaid wrap third-party accounts receivables and allowances were not adequately analyzed and adjusted timely. Questioned Cost: N/A Context: During the analysis of Medicaid wrap accounts receivable, we questioned the collectibility of this receivable which resulted in a significant adjustment being made. Identification of Repeat Finding: This finding was originally reported in 2019-001. Recommendation: We recommend that FMCS run subsequent receipt reports as late in the following year as possible, as a part of analyzing the reasonableness of accounts receivable. View of responsible officials and planned corrective actions: Effective October 2020, all DC Medicaid Managed Care Organizations (MCOs) began paying the full Federally Qualified Health Centers (FQHC) rate directly to the health center. Therefore, giving us the ability to recognize revenue and receivable from the same insurance payor. This should resolve most of the issues we have with identifying wrap payments for MCOs claims. In terms of the existing receivable balance under Medicaid and Medicaid wrap account, we will review the subsequent receipts from Department of Health Care Finance (DHCF) in 2022 during the closing of year-end 2021 accounts. We will then make an appropriate write off adjustment to remove the remaining balance from Medicaid and Medicaid wrap receivable account in year-end 2021.
Show full finding ▾Hide full finding ▴Finding 2020-001: Internal Control over Financial Reporting, Assistance Listing Numbers - All Criteria: Internal control is a process?effected by those charged with governance, management, and other personnel?designed to provide reasonable assurance about the achievement of the entity's objectives with regard to the reliability of financial reporting, effectiveness and efficiency of operations, and compliance with applicable laws and regulations. Condition: Although Medicaid wrap third-party payor accounts receivable balances were analyzed and adjusted prior to the start of the audit, subsequent receipts needed to be reviewed further to determine collectibility and reasonableness of the balance. A significant adjustment was made to the accounts receivable balance at the end of the audit, as a result of additional analysis. Effect: Periodic reporting may be inaccurate if analysis is not done timely. Cause: Medicaid wrap third-party accounts receivables and allowances were not adequately analyzed and adjusted timely. Questioned Cost: N/A Context: During the analysis of Medicaid wrap accounts receivable, we questioned the collectibility of this receivable which resulted in a significant adjustment being made. Identification of Repeat Finding: This finding was originally reported in 2019-001. Recommendation: We recommend that FMCS run subsequent receipt reports as late in the following year as possible, as a part of analyzing the reasonableness of accounts receivable. View of responsible officials and planned corrective actions: Effective October 2020, all DC Medicaid Managed Care Organizations (MCOs) began paying the full Federally Qualified Health Centers (FQHC) rate directly to the health center. Therefore, giving us the ability to recognize revenue and receivable from the same insurance payor. This should resolve most of the issues we have with identifying wrap payments for MCOs claims. In terms of the existing receivable balance under Medicaid and Medicaid wrap account, we will review the subsequent receipts from Department of Health Care Finance (DHCF) in 2022 during the closing of year-end 2021 accounts. We will then make an appropriate write off adjustment to remove the remaining balance from Medicaid and Medicaid wrap receivable account in year-end 2021.
Assistance Listing No.: All 2020-001: Internal Control over Financial Reporting ? Significant deficiency Recommendation: We recommend that FMCS run subsequent receipt reports as late in the following year as possible, as a part of analyzing the reasonableness of accounts receivable. Corrective Action: Effective October 2020, all DC Medicaid Managed Care Organizations (MCOs) began paying the full Federally Qualified Health Centers (FQHC) rate directly to the health center. Therefore, giving us the ability to recognize revenue and receivable from the same insurance payor. This should resolve most of the issues we have with identifying wrap payments for MCOs claims. In terms of the existing receivable balance under Medicaid and Medicaid wrap account, we will review the subsequent receipts from Department of Health Care Finance (DHCF) in 2022 during the closing of year-end 2021 accounts. We will then make an appropriate write off adjustment to remove the remaining balance from Medicaid and Medicaid wrap receivable account in year-end 2021.
2019-001
FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2020 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. Our request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of our audit. Repeat Finding: No Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy. View of responsible officials and planned corrective actions: FMCS concurs with the finding and recommendation of the auditor. The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022.
Show full finding ▾Hide full finding ▴Finding 2020-002: Procurement Suspension and Debarment U.S. Department of Health and Human Services ? Assistance listing No. 93.224, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For The Homeless, And Public Housing Primary Care). Criteria: In accordance with 2 CFR section 200.214, Suspension and debarment, ?The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Condition: FMCS did not have evidence of verification that vendors are not suspended or debarred from federal and/or state contracts. Cause: FMCS has a procurement policy which indicates ?Certain contracts will not be made to parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension.? (See 45 C.F.R. Part 76). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory authority other than E.O. 12549.? However, there is no evidence this policy was followed during 2020 for vendors/contractors engaged. Effect: FMCS has not documented that it performed required verification. Questioned Costs: Unknown Context: FMCS?s procurement policy specifies contracts will not be awarded to ?parties listed on the nonprocurement portion of the General Services Administration?s `List of Parties Excluded from Federal Procurement or Nonprocurement Programs? in accordance with Executive Orders 12549 and 12689, `Debarment and Suspension??. Our request for evidence of verification that vendors were not suspended or disbarred was not provided prior to conclusion of our audit. Repeat Finding: No Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with policy. View of responsible officials and planned corrective actions: FMCS concurs with the finding and recommendation of the auditor. The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022.
Assistance Listing No. 93.224: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, And Public Housing Primary Care) 2020-002: Procurement Suspension and Debarment ? Significant deficiency Recommendation: FMCS should provide training on procurement policy and update policy to include retention of support for compliance with requirement. Corrective Action:FMCS concurs with the finding and recommendation of the auditor. The procurement policy will be revised to include retention of support for compliance before the March board meeting. Training on our procurement policy will be provided by March 31, 2022.
2019-001
FAC accepted this audit on December 23, 2020 — management decision was due June 23, 2021.
FAC accepted this audit on September 29, 2019 — management decision was due March 29, 2020.
FAC accepted this audit on September 28, 2018 — management decision was due March 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
FAC accepted this audit on September 27, 2017 — management decision was due March 27, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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