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FINDING REFERENCE NUMBER 2019-004 (See FINDING REFERENCE NUMBER 2019-001) FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT ACTIVITIES ALLOWED OR UNALLOWED/ALLOWABLE COSTS/COST PRINCIPLES TYPE OF FINDING NONCOMPLIANCE AND SIGNIFICANT DEFICIENCY CRITERIA OR SPECIFIC REQUIREMENT 45 CFR Section 75.303, establishes that non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO); (b) comply with Federal statutes, regulations, and the terms and conditions of the Federal awards; and, (c) evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. In addition, 45 CFR Section 75.403, estates general criteria to determine allowability of costs under federal awards, such as: be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; and be adequately documented; among others. CONDITION As part of our audit procedures over allowable cost/cost principles, we noted the following deficiencies over this compliance requirement: a) We reviewed the cash account in which the drawdowns of the HCP program are deposited. Transfers were made to the operational cash account during the first quarter of the fiscal year, and HPM was not able to account or provide evidence for each of the transfers made to the operational account. QUESTIONED COSTS Not determined CONTEXT This was a systemic problem. In the first quarter of the fiscal year, the entity was not able to provide evidence of the transfers made to the operational and payroll account. EFFECT OR POSSIBLE EFFECT HPM could have incurred in unallowable costs or activities, and not be able to prevent or detect a transaction that didn't comply with the Federal regulation. CAUSE HPM didn't have adequate internal controls in place, or documentation that presented adequate segregation of duties and compliance with applicable laws and regulations. In addition, no internal controls were documented that supported proper accountability of funds for the first quarter. IDENTIFICATION AS A REPEAT FINDING Finding Number 2018-006 RECOMMENDATION We recommend management to continue monitoring their internal controls in order to properly document all cash disbursed from Federal funds. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION This situation was identified for the first quarter of the fiscal year 2019 (April to June 2018) only, so in the next 9 months there were no deficiencies in the documentation of drawdowns. Corrective Action Plan: (1) After June 2018, we have incorporated and implemented internal controls for the accounting of Federal funds, the expenditure analysis, the certification of allowability of costs and the documentation of segregation of duties in the approval and request of Federal cash drawdown process. On July 15, 2019, we revised our Federal Cash Management Drawdown Policy, HPM #2019-CM-003, (Originally dated December 7, 2018 and revised on July 15, 2019); (2) During the fiscal year 2019, HPM provided training to those employees that approves and accounts for the Federal funds to assure properly documentation of cash disbursed from Federal funds. IMPLEMENTATION DATE Completed on: July 19, 2019 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT CASH MANAGEMENT TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA OR SPECIFIC REQUIREMENT 45 CFR Section 75.305(b)(1), establishes that non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. CONDITION As part of our audit procedures over cash management, we noted the following deficiencies over this compliance requirement: a) HPM provided a detail of all drawdowns made during the fiscal year 2018-2019. The total of population of drawdowns are forty-one (41). The fifteen (15) drawdowns selected for internal control testing, were used to test compliance with the cash management requirement. HPM was not able to provide supporting documentation for four (4) drawdowns which were made during the first quarter of the fiscal year, out of the fifteen (15) drawdowns selected. b) We noted that HPM made drawdowns in the amount of $156,590.50 bi-weekly and transfer this amount to the payroll cash account without documenting the amount of payroll covered by Federal funds, in the first quarter of the fiscal year. c) We examined the bank statements, and during the year, HPM earned $772.58. No evidence was provided indicating that this amount was notified or remitted to the U.S. Department of Health and Human Services. QUESTIONED COSTS Not determined CONTEXT This is a systemic problem. No documentation was established in HPM to provide evidence of the analysis performed to ascertain reasonability of the drawdowns made in the first quarter of the fiscal year. EFFECT OR POSSIBLE EFFECT HPM is not in compliance with the cash management requirements for advance payment and might change the funding to a reimbursement system payment. This situation might affect the cash flow of HPM. CAUSE HPM didn't monitor the cash drawdowns during the first quarter of the fiscal year in order to determine that they were made for immediate cash needs. Further, no analysis or documentation was provided that presented evidence of the drawdown immediate need. In addition, a projected amount was used biweekly to draw a fixed amount during the first quarter of the fiscal year. IDENTIFICATION AS A REPEAT FINDING Finding Number 2018-007. RECOMMENDATION We recommend management to continue the monitoring of the cash management requirements, and monitor the interest earned in order to properly inform HHS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION Condition (a) and (b) This situation was identified for the first quarter of the fiscal year 2019 (April to June 2018) only, so in the next 9 months there were no deficiencies in the documentation of drawdowns. The four (4) drawdowns for which supporting documentation was not provided pertain to the first quarter of the fiscal year 2019 (April to June 2018), so this situation didn?t occur for the following nine (9) months of the fiscal year. Corrective Action: (a), (b) After June 2018, we have incorporated and implemented internal controls for the accounting of Federal funds, the expenditure analysis, the certification of allowability of costs and the documentation of segregation of duties in the approval and request of Federal cash drawdown process. On July 15, 2019, we revised our Federal Cash Management Drawdown Policy, HPM #2019-CM-003, dated December 7, 2018 (see Attachment). Some key procedures stated in our policy provide assurance for the documentation of drawdowns, expenditures analysis and certification for the allowability of costs as required by the Federal statutes, regulations and the terms and conditions of the Federal award. During the fiscal year 2019, HPM provided training to those employees that approves and accounts for the Federal funds to assure compliance with cash management requirements. Corrective Action: (c) During the monthly bank account reconciliation, the finance staff must perform specific verifications to determine the interest earned in order to properly inform HHS and make the required reimbursements. This procedures is part of the Bank Statements Policy Draft (HPM Policy 2019-11, Expected Approval by the Board by March 31, 2020). The CFO will notify HRSA in order to reimburse the $772.58 of interest received by February 28, 2020. IMPLEMENTATION DATE (a and (b): Completed on July 15, 2019 (c): Target Completion Date: February 28, 2020 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT EQUIPMENT/REAL PROPERTY MANAGEMENT TYPE OF FINDING NONCOMPLIANCE AND SIGNIFICANT DEFICIENCY CRITERIA OR SPECIFIC REQUIREMENT 45 CFR Section 75.320(d), establishes that non-Federal entity must have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. CONDITION As part of our audit procedures over equipment and real property management, we noted that HPM written internal control procedures over equipment and real property, didn?t include any detail of procedures, capitalization policy, among others, just a general requirement. QUESTIONED COSTS Not determined CONTEXT This is a systemic problem. No internal control policy and procedures were in place in order to assure compliance with this requirement. EFFECT OR POSSIBLE EFFECT HPM doesn?t have written procedures to assure that inventories and usage of property and equipment is in compliance with the Federal regulation. CAUSE No written internal control procedures were established to assure that accountability and records over equipment and real property were in accordance with Federal regulation. IDENTIFICATION AS A REPEAT FINDING Finding Number 2018-008RECOMMENDATION We recommend management to prepare and implement written internal control procedures that contains all requirements from Federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION HPM revised the Property Control Policy in order to implement internal control procedures for managing the property and equipment in accordance with the Federal statutes, regulations, terms and conditions of the Health Center Program award and with HRSA requirements. (HPM Policy 2019-04, approved by the Board of Directors on November 5, 2019). The revised Property Control Policy was submitted to HRSA as part of the corrective action plan for the Single Audit Report 2018, Finding 2018-08, which was cleared by HRSA after reviewing the revised policy (See attachment of the Policy and HRSA Letter dated December 17, 2019). IMPLEMENTATION DATE Completed on: November 5, 2019 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT PERIOD OF PERFORMANCE TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA OR SPECIFIC REQUIREMENT A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 75.461) and any costs incurred before the HHS awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Funds available to pay allowable costs during the period of performance include both Federal funds awarded and carryover balances. A non-Federal entity must liquidate all obligations incurred under the award not later than 90 days after the end of the funding period (or as specified in a program regulation) to coincide with the submission of the final Federal Financial Report (FFR). This deadline may be extended with prior written approval from the HHS awarding agency. CONDITION As part of our audit procedures over period of performance, we noted that the funds reported as expended on the FFR-425 didn?t reconcile with expenditures incurred at March 31, 2019, under cash basis of accounting. Further, no unliquidated obligations were reported, although, accounts payable were reported and paid within the 90 days established by the regulation. QUESTIONED COSTS Not determined CONTEXT This is a systemic problem. No adequate controls are in place to ascertain that the period of performance of each award is in compliance. EFFECT OR POSSIBLE EFFECT HPM is not in compliance with the period of performance requirements and might change the funding to a reimbursement system payment. This situation might also lead to the suspension of future federal funding to the Entity. CAUSE HPM didn't monitor the period of performance deadlines in order to determine that all obligations were liquidated under the requirements' date. Further, no analysis or documentation was provided that presented evidence that all obligations were liquidated under the NOA period of performance. IDENTIFICATION AS A REPEAT FINDING Finding Number 2018-009 RECOMMENDATION We recommend management to implement internal controls to assure compliance with performance periods and follow the requirements of the awarding agency. In addition, HPM must establish a firm budget so that the needs to request new NOA's can decrease and adequate internal controls can be uniformly implemented. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION On November 5, 2019, HPM?s Board of Directors approved the Period of Performance, Allowability of Costs, Financial Management and Reporting Policy (HPM Policy 2019-07). This policy was established in order to implement control procedures in the HPM?s financial management system and to provide assurance of compliance with the required standards in the accounting, monitoring and reporting functions of the Federal awards received and expended, in accordance with the Federal statutes, regulations, terms and conditions of the Health Center Program award and with HRSA requirements. IMPLEMENTATION DATE Completed on: November 2, 2019 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT REPORTING TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA OR SPECIFIC REQUIREMENT 45 CFR Section 75.302(b), establishes that the financial management system of each non-Federal entity must provide for the following : (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the HHS awarding agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ? 75.341 and ? 75.342. If an HHS awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Similarly, a pass-through entity must not require a subrecipient to establish an accrual accounting system and must allow the subrecipient to develop accrual data for its reports on the basis of an analysis of the documentation on hand. (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. See ? 75.303. In addition, 45 CFR ? 75.341, establishes that unless otherwise approved by OMB, the HHS awarding agency may solicit only the standard, OMB-approved government-wide data elements for collection of financial information (at time of publication the Federal Financial Report or such future collections as may be approved by OMB and listed on the OMB Web site). This information must be collected with the frequency required by the terms and conditions of the Federal award. According to their Notice of Obligations, the Federal Financial Report (FFR) should be submitted by July 30. The Uniform Data System (UDS) report, is due 45 days after the end of reporting period, that is February 15, 2018. CONDITION As part of our audit procedures over reporting, we noted the following deficiencies over this compliance requirement: a) The FFR (SF-425) corresponding to the year ended March 31, 2019, the expenditure reported didn?t agree with the actual expenditures incurred and any obligation at year end. The expenditures incurred at March 31, 2019 were $5,529,415, HPM reported $5,696,979.56. b) The UDS report corresponding to calendar year ended December 31, 2018, reported on Table 9E, Line 1g, Column a, $5,635,537, corresponding to drawdowns from the period of January through December 2018. The amount drawn according to PMS provided by client, amounted to $5,979,931. In addition, on Table 5, Line 15, Column b, reported 57,146 non-nursing medical visits, according to evidence provided, this amount should be 56,921. QUESTIONED COSTS Not determined CONTEXT This is a systemic problem. EFFECT OR POSSIBLE EFFECT We were unable to ascertain the accuracy of the data presented in the FFR-425 and UDS lines mentioned above. CAUSE HPM didn?t reconciled the amount reported in their financial reports (FFR and UDS) with their accounting records. IDENTIFICATION AS A REPEAT FINDING Finding Number 2018-011. RECOMMENDATION We recommend management to implement internal controls to maintain evidence of the amounts presented in the reports. In addition, the financial management system, should provide accountability of each fund administered by HPM. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION On November 5, 2019, HPM?s Board of Directors approved the Period of Performance, Allowability of Costs, Financial Management and Reporting Policy (HPM Policy 2019-07). This policy was established in order to implement control procedures in the HPM?s financial management system and to provide assurance of compliance with the required standards in the accounting, monitoring and reporting functions of the Federal awards received and expended, in accordance with the Federal statutes, regulations, terms and conditions of the Health Center Program award and with HRSA requirements. The Policy was submitted to HRSA as part of the corrective action plan for the Single Audit6 Report FY2018, Finding 2018-11, which was cleared by HRSA after reviewing the policy (See attachment for the Policy and HRSA Letter dated December 17, 2019). IMPLEMENTATION DATE Completed on: November 5, 2019 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM HEALTH CENTER PROGRAM CLUSTER (HCPC) (CFDA 93.224 AND 93.527) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBER H80CS00695 COMPLIANCE REQUIREMENT SPECIAL TESTS AND PROVISIONS ? SLIDING FEES TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA OR SPECIFIC REQUIREMENT 42 CFR Section 56.303(f)(g), establishes project elements that a migrant health center supported must: (f) Have prepared a schedule of fees or payments for the provision of its services designed to cover its reasonable costs of operation and a corresponding schedule of discounts adjusted on the basis of the patient's ability to pay. The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the most recent CSA Poverty Income Guidelines (42 CFR 1060.2) (except that nominal fees for service may be collected from such individuals and families) and for no discount to individuals and families with annual incomes greater than twice those set forth in such Guidelines. (g) Make every reasonable effort, including the establishment of systems for eligibility determination, billing, and collection, to: (1) Collect reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act, to medical assistance under a State plan approved under title XIX of such Act, to social services and family planning under title XX of such Act, or to assistance for medical expenses under any other public assistance program, grant program, or private health insurance or benefit program on the basis of the schedule of fees prepared pursuant to paragraph (f) of this section without application of any discounts, and (2) Secure from patients? payments for services in accordance with the schedule of fees and discounts required by paragraph (f) of this section. CONDITION As part of our audit procedures over the Special Test and Provisions - Sliding Fee Discounts, we noted the following deficiencies over this compliance requirement: a) From a population of 791 participants of the program, we initially selected 90 participants in order to determine if proper internal control procedures over Sliding Fee Discount requirement were established, and the respective compliance. We noted that for twenty one (21) participants, the sliding fee applied was not in compliance with their policies. b) We were not able to examine supporting documentation that supported the Sliding Fee Discount applied to the participants from Carolina Center, from the originally 90 participants, sixty-three (63) participants files were not available to examine. We selected forty three (43) additional participants from all locations, and ten (10) files were not available. QUESTIONED COSTS Not determined CONTEXT This is a systemic problem. EFFECT OR POSSIBLE EFFECT HPM didn't comply with record retention of the determination of Sliding Fees Discounts to participants. HPM was not able to demonstrate that the applicable Sliding Fees Discount was provided to participants. In addition, for some participants, revision of the applied Sliding Fee Discount, was not properly performed, and may apply incorrect discount. CAUSE HPM didn't have in place appropriate internal controls in order to assure compliance with record retention and applicability of Sliding Fees Discount applied to participants. In addition, the personnel in charge of the determination of Sliding Fees Discount in the Carolina Center, didn?t have proper training regarding this compliance requirement. IDENTIFICATION AS A REPEAT FINDING This is not a prior audit finding. RECOMMENDATION We recommend management to implement internal controls to assure compliance with applicable Sliding Fees Discount and proper document retention records. Continuing monitoring of determinations made for Sliding Fees, should be performed. In addition, proper training should periodically be given to personnel in charge of applying the Sliding Fees Discount. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION On October 29, 2019, HPM?s Board of Directors approved the Documentation and Retention Policy (HPM Policy 2019-6A), which was established in order to implement controls and procedures to be assured that records are kept for the required period of time before being destroyed and in compliance with the retention periods required by Federal or State government and agencies, and to be certain that documents needed for audits are available. The retention requirements for financial records, supporting documents, statistical records, and all other records pertinent to a Federal award must be retained for a period of three (3) years from the date of submission of the final expenditure report. The retention requirements for patient medical and financial records are: 3 years after the last date of service rendered to a patient. (2) HPM?s The Sliding Fee Policy (#FIN-2019-02) was approved by the Board of Directors on May 29, 2019. (3) From January 2020, HPM Finance staff start providing educational sessions and training about the Sliding Fee Policy to personnel in charge of applying the Sliding Fees Discount. Also, new employees are trained about the Sliding Fee Policy. IMPLEMENTATION DATE Completed on: May 29, 2019, October 29, 2019 and January 2020 RESPONSIBLE PERSON Mr. William Soberal, CFO

FEDERAL PROGRAM ALL PROGRAMS AWARD NUMBER ALL COMPLIANCE REQUIREMENT REPORTING TYPE OF FINDING NONCOMPLIANCE AND SIGNIFICANT DEFICIENCY CRITERIA OR SPECIFIC REQUIREMENT 2 CFR ?200.512 Report Submission, (a) (1) The audit must be completed and the Data Collection Form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. CONDITION HPM did not submit the Data Collection Form and Reporting Package to the Federal Audit Clearinghouse of fiscal year ending March 31, 2019 during the required period. QUESTIONED COSTS Not determined CONTEXT HPM was still in the process of having their accounting records on time, and in addition, they ended their previous Single Audit on June 30, 2019, after having an approval from the federal agency to submit their Single Audit after their due date. EFFECT OR POSSIBLE EFFECT HPM did not comply with the submission date required for the Data Collection Form and Reporting Package, this could affect the continuance and new approvals of federal funds. In addition, for the next two (2) fiscal years the Entity can?t be considered by the auditor as a low risk auditee. CAUSE HPM was not able to have all required financial information on time in order to be audited. IDENTIFICATION AS A REPEAT FINDING This is not a prior audit finding. RECOMMENDATION We recommend management to implement internal controls to assure that all required accounting information is available and timely processed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION (1) Due to the accumulated effects of hurricanes Irma and Maria (the hurricanes) the Data Collection Form and Reporting Package for the fiscal year ending March 31, 2019 was submitted after the required submission date. This delay is due to the late submission occasioned by the hurricanes to the Data Collection Form and Reporting Package for the fiscal year ending March 31, 2018, which were submitted on June 30, 2019, according to the extension of time requested and granted, based on the Memorandum from the Office of Management and Budget (OMB), Administrative Relief for Grantees impacted by Hurricanes Harvey, Irma and Maria, dated October 26, 2017. For those reasons, the audit procedures for the fiscal year ended March 31, 2019 could not be completed before December 31, 2019.(2) HPM Annual Audits Policy Draft (HPM Policy 2019-11) is established in order to implement internal control procedures to assure compliance with the audit requirements applicable to non-Federal entities the expend Federal awards. (This policy is expected to be submitted for the Board approval by March 31, 2020.) IMPLEMENTATION DATE Target Completion Date: March 31, 2020 RESPONSIBLE PERSON Mr. William Soberal, CFO

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