Community Health and Wellness Center of Greater Torrington, Inc.

Finding 2025.001: Procurement, Suspension and Debarment - Significant Deficiency 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) Grants for New and Expanded Services under the Health Center Program COVID-19 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: H8012843 - 2025 and 2024, H8L51743 - 2023 and H2E50081 2024 and 2023 Criteria In accordance with §200.213 and §180.300, nonfederal 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 The Center did not have adequate evidence that they reviewed vendors for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate internal controls in place to illustrate a review for suspended or debarred vendors. Effect or Potential Effect The Center may have vendors that have been suspended or debarred from doing business with the federal government. Questioned costs None. Context A selection of four vendors was made for suspension and debarment testing. For three of the vendors tested, management did not provide adequate supporting documentation for the review and approval of the vendors as to whether they have been suspended or debarred. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation The Center should establish a system of internal controls to review vendors in accordance with the Uniform Guidance requirements for suspension and debarment. These procedures should be reviewed with the appropriate staff to ensure compliance with requirements. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Finding 2024.001: Special Tests and Provisions - Sliding Fee Scale Discounts - Significant Deficiency 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) Grants for New and Expanded Services Under the Health Center Program COVID-19 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: H8012843 - 2023 and 2024, H8L51743 - 2023 and H8G48165 - 2022 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5),56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review slide fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always calculate the proper sliding fee discount based on the Center's approved sliding fee discount policy or have the appropriate documentation. Cause The Center did not have adequate internal controls in place to effectively ensure that the patient received the correct sliding fee discount based on the Center's approved sliding fee discount policy. Effect or Potential Effect The Center did not comply with the appropriate Special Tests and Provisions rules and regulations as per the Uniform Guidance. Questioned Costs None Context A test of 40 slide fee discount transactions was performed and resulted in four instances of sliding fee discounts not being properly calculated based on the respective household size and income. For one of these instances, there was no sliding fee application. Our sample was a statistically valid sample. Identification of Repeat Finding Yes, see finding 2023.001 Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Finding 2023-001: Sliding Fee Scale Documentation 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, COVID-19 Grants for New and Expanded Services Under the Health Center Program. Federal Assistance Listing Numbers: 93.224 and 93.527 Criteria Health centers are required to have a corresponding schedule of discounts applied and adjusted on the basis of patients' ability to pay and their eligibility. A patient's eligibility to pay is determined on the basis of the official poverty guideline, as revised by DHHS (42 CFR Sections 51c, 107(b)(5),56.108(b)(5) and 56.303(f)). The Center should be implementing and monitoring procedures to properly determine, calculate and review slide fee discounts issued to patients in accordance with the Center's sliding fee scale. Condition The Center did not always have the proper slide fee documentation readily available to ensure the proper slide fee discount was applied based on approved policies. Context A test of 25 slide fee discount transactions was performed and resulted in one instance of a sliding fee discount not being properly calculated based on the respective patient family size and income. Our sample was a statistically valid sample. Cause The Center did not have adequate internal controls in place to effectively ensure that all sliding fee discounts were properly calculated based on approved documentation. Effect The Center did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding No. Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

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