HEALTHCARE FOR THE HOMELESS-HOUSTONNon-Profit

Finding No. 2025-001 Management is Responsible for Obtaining and Retaining Patient Intake Forms to Remain Compliant with Sliding Fee Discount Requirements. Condition: Certain patient intake forms were either not obtained or not updated for the current year’s visit. Criteria or specific requirement: Health centers are required to prepare and apply a sliding fee discount schedule so that amounts owed for health center services by eligible patients are adjusted based on the patient’s ability to pay. Adequate documentation must be maintained to support the determination and application of sliding fee discounts. Effect: Documentation supporting patient intake and eligibility for sliding fee discounts was not always retained. Cause: Of the patients selected for testing, one patient did not have an intake form on file and three patients had intake forms from years prior to 2025. This appears to be primarily due to operational transitions experienced by the Organization, which contributed to challenges in maintaining consistent execution and oversight of registration processes. Recommendation: We recommend that the Organization strengthen its procedures to ensure patient intake forms are obtained, updated as required, reviewed, approved, and retained in patient files. Management’s view: Management agrees with the condition described. Proposed corrective action: Management will strengthen procedures for obtaining and retaining patient intake documentation to ensure ongoing compliance with sliding fee discount requirements. Front-desk and registration staff will be retrained on intake form completion and annual renewal requirements, with clear accountability assigned for verifying documentation at each patient visit. A weekly compliance monitoring report will be implemented to identify missing or outdated intake forms before they age past the current review period, allowing for timely follow-up. Registration workflows will be refined to build in a review checkpoint at the point of service, and the Organization will add dedicated intake staffing capacity to provide consistent oversight of this function going forward. These steps will strengthen controls and ensure patient intake documentation is properly obtained, updated, and retained in compliance with sliding fee discount requirements. Anticipated correction date: Some corrective action was implemented in Q1 and Q2 2026. This is expected to be fully implemented effective by Q4 2026. Responsible official: Kathryn Rogers, Executive Vice President.

Condition: The Organization did not adequately document draw down requests or present the federal award revenue in accordance with GAAP. Criteria or specific requirement: Activities Allowed/Unallowed and Cost Principles (45 CFR 75.403(g)) requires costs to be adequately documented. Questioned Costs: $49,402Effect: Grant funds were used for nonallowable expenses as defined within the grant agreement Cause: The Organization did not use grant funds under this award for allowable costs as defined within the grant agreement. Identification: Not a repeat finding Recommendation: Management should solidify grants management procedures, specifically regarding the documentation of drawdowns of grant funds and review expenditures allowed and unallowed per the terms of the grant agreement. Management?s view: Management agrees with the condition described. Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviews the documentation for expenditures allowed and unallowed under the terms of the grant agreement, and the drawdown happens only when the amount of allowed expenditures has been determined. Anticipated correction date: This has already been implemented retroactively effective January 2023. Responsible official: Gabriela Cordero, Chief Financial Officer.

Condition: During our testing, we noted that certain draw requests of federal funds were not supported by documentation of the review and approval of those draw requests. Criteria or specific requirement: Cash management (45 CFR 75.342(a)) Monitoring and reporting program performance requires the Organization to monitor and oversee operations of the Federal award supported activities. Effect: Documentation of the initial review and approval of federal funds draw requests was not retained. Cause: Based on our observations, upon change in the Chief Executive Officer role and the abrupt loss of the Chief Financial Officer, existing procedures were not completely transferred to the new officer and employees, and/or service providers. Recommendation: We recommend that documentation of the review and approval of draws on federals funds be obtained and saved prior to requests being submitted. Management?s view: Management agrees with the condition described. Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviewed draws on federal funds noting no discrepancies. Going forward, the Chief Financial Officer will calculate the amount of the draw on federal funds, which will then be reviewed, approved, and documented by the Chief Executive Officer before the draw is submitted. Anticipated correction date: This has already been implemented retroactively effective January 2023. Responsible official: Gabriela Cordero, Chief Financial Officer.