COUNCIL FOR THE ADVANCEMENT OF SOCIAL SERVICES AND EDUCATIONNon-Profit

2023-003 Federal Clearinghouse Late Filing ALN: 93.224 Program: Community Health Center Cluster, Section 330 Agency: US Department of Health and Human Services Compliance Requirement: L Reporting Criteria: Recipients of federal funds at the major program level are required to submit audited consolidated financial statements to the federal clearinghouse either nine months after year end or thirty days after the audit report is accepted by those charged with governance. Finding/ Condition: The Organization failed to comply with the time requirement for federal clearinghouse submissions. Questioned Cost: None. Effect: The Organization is in violation of Federal Clearinghouse regulations. Cause: Personnel availability delayed the completion of the audit. Repeat Finding: No. Recommendation: We recommend that the Organization begin the audit process earlier in the year to allow for unforeseen delays. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 34.

2023-004 Cash Management Compliance ALN: 10.766 Program: Emergency Rural Health Care Grant Agency: US Department of Agriculture Compliance Requirement: C Cash Management Criteria: The compliance supplement requires organizations receiving federal funds to establish controls and procedures that would minimize the amount of time between drawdowns and the disbursements of grant funds. Finding/ Condition: Federal grant funds were received prior to obligation/disbursement of funds. Questioned Cost: None. Effect: Reimbursement occurred before needed for disbursement purposes. Cause: Miscommunication between grant staff and federal agency staff caused payment to be requested prior to expenditures being made. Repeat Finding: No. Recommendation: We recommend training for staff to ensure cash management requirements are followed. Management should track the status of the federally funded cash disbursements against the need to draw down funds on related grants. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding. Please refer to the corrective action plan on page 34.

2023-005 Noncompliance Related to Conflict-of-Interest Policies ALN: 10.766 Program: Emergency Rural Health Care Grant Agency: US Department of Agriculture Compliance Requirement: I Procurement Suspension & Debarment Criteria: Per the entity’s conflict-of-interest policy and Uniform Guidance, officers and key employees must disclose any actual or apparent conflicts of interest, including related party transactions. Such transactions should be reviewed and approved by those charged with governance. Finding/ Condition: During our audit, we identified transactions between the Organization and a vendor owned or controlled by officers and family members of officers of the Organization. These transactions were not appropriately disclosed to the Board of Directors and were not subject to documented review or approval in accordance with the Organization’s conflict-of-interest policy. Questioned Cost: $140,921 Effect: Failure to disclosure conflicts of interest increases the risk of improper use of federal funds. This lack of transparency and oversight by management can set an inappropriate tone for the organization. This also increases the risk of noncompliance with federal requirements. Cause: Management did not adhere to established conflict-of-interest policies and procedures. Additionally, internal controls were not designed or operating effectively to identify and monitor related party transactions. Repeat Finding: No. Recommendation: We recommend that management: • Strengthen controls over identifying and disclosing related party transactions. • Require annual conflict-of-interest disclosures from all key personnel. • Ensure all related party transactions are fully disclosed, reviewed for reasonableness and approved by the Board or an independent committee. • Provide training on compliance with federal requirements. Views of Responsible Officials and Corrective Action Plan: Please see page 35 for the views of responsible officials and corrective action plan.

2021-001 Federal Clearinghouse Late Filing CFDA Number: 93.224 Program: Community Health Center Cluster, Section 330 Agency: US Department of Health and Human Services Compliance Requirement: L- Reporting Criteria: Recipients of federal funds at the major program level are required to submit audited financial statements to the federal clearinghouse either nine months after year end or thirty days after the audit report is accepted by those charged with governance. Finding/ Condition: The Organization failed to comply with the time requirement for federal clearinghouse submissions. Questioned Cost: None. Effect: The Organization is in violation of Federal Clearinghouse regulations. Cause: Personnel availability delayed the completion of the audit. Repeat Finding: Yes. Please see 2020-001. Recommendation: We recommend that the Organization begin the audit process earlier in the year to allow for unforeseen delays. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

2021-002 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, sixteen samples were not adjusted according to the sliding fee policy in a timely manner. Because these encounters were not adjusted timely, errors in adjustments given or lack of documentation was not discovered timely. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Due to the COVID-19 pandemic, staffing shortages made it difficult to adjust encounters timely. Repeat Finding: Yes. Please see 2020-002. Recommendation: Billing staff should be increased to be able to meet the sliding fee program requirements. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

2020-001 Federal Clearinghouse Late Filing CFDA Number: 93.224 Program: Community Health Center Cluster, Section 330 Agency: US Department of Health and Human Services Compliance Requirement: L- Reporting Criteria: Recipients of federal funds at the major program level are required to submit audited financial statements to the federal clearinghouse either nine months after year end or thirty days after the audit report is accepted by those charged with governance. Finding/ Condition: The Organization failed to comply with the time requirement for federal clearinghouse submissions. Questioned Cost: None. Effect: The Organization is in violation of Federal Clearinghouse regulations. Cause: Personnel availability delayed the completion of the audit. Repeat Finding: Yes. Please see 2019-002. Recommendation: We recommend that the Organization begin the audit process earlier in the year to allow for unforeseen delays. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

2020-002 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, sixteen samples were not adjusted according to the sliding fee policy in a timely manner. Because these encounters were not adjusted timely, errors in adjustments given or lack of documentation was not discovered timely. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Due to the COVID-19 pandemic, staffing shortages made it difficult to adjust encounters timely. Repeat Finding: Yes. Please see 2019-003. Recommendation: Billing staff should be increased to be able to meet the sliding fee program requirements. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

2019-002 Federal Clearinghouse Late Filing CFDA Number: 93.224 Program: Community Health Center Cluster, Section 330 Agency: US Department of Health and Human Services Compliance Requirement: L- Reporting Criteria: Recipients of federal funds at the major program level are required to submit audited financial statements to the federal clearinghouse either nine months after year end or thirty days after the audit report is accepted by those charged with governance. Finding/ Condition: The Organization failed to comply with the time requirement for federal clearinghouse submissions. Questioned Cost: None. Effect: The Organization is in violation of Federal Clearinghouse regulations. Cause: Personnel availability delayed the completion of the audit. Repeat Finding: Yes. Please see 2018-001. Recommendation: We recommend that the Organization begin the audit process earlier in the year to allow for unforeseen delays. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

2019-003 Sliding Fee Discount Determination CFDA Number: 93.224 Program: Community Health Center Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Criteria: Federal grant compliance provisions require that the Organization correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. The Organization is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, in five samples patient information was inadequate to determine the proper sliding fee discount and in one sample the patient was given incorrect discounts based on information provided. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in the Organization providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and Organization policies by employees involved in sliding fee determination and billing. Recommendation: Training should be provided to employees on the sliding fee program requirements. Views of Responsible Officials and Corrective Action Plan: The Organization agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 28.

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