Center for Mental Health dba Many Rivers Whole HealthNon-Profit

Cash Management U.S. Department of Public Health ALN: 93.696, The Central Montana CCBHC Improvement and Advancement Project Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition: The Center drew down funds during the audit period, but there was no indication of approval for the drawn amounts. Context: The Center had five drawdowns totaling $1,007,504. There was no documentation provided for review of these draws. Effect: There is an increased risk of errors in drawn amounts if internal controls are not in place for review. Questioned Costs: There were no questioned costs identified. Cause: The Center experienced turnover and are working on improving internal controls over cash management. Documenting and retaining this documentation of the review started after the audit period in November 2025. Auditor Recommendation: We recommend that the Center retain documentation supporting the established internal controls over cash management, which includes a review process before the draws are made. Organization Response: Implemented in November 2025. The Controller prepares the monthly draw, and the CFO reviews, approves, and submits it. The approval email is retained with the payment submission documentation. Responsibility for maintaining this process rests with the Controller and CFO.

Allowable Costs and Cost Principles U.S. Department of Public Health ALN: 93.696, The Central Montana CCBHC Improvement and Advancement Project Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. he award budget permits the allocation of shared direct costs based on estimated allocations in accordance with the Center's direct cost allocation plan. In addition, bad debts, including losses arising from uncollectible accounts and other claims, are unallowable under 2 CFR 200.426. Condition: The Center included unallowable bad debt expenses totaling ($429,010) in the shared direct cost allocation calculation. In addition, overhead costs totaling $332,910 were included in the calculation. The combined net effect of these two items was $96,100, of which 10 percent ($9,610) was allocated as shared direct costs. Context: Bad debt expenses were included in the shared direct cost calculation for May and June 2025. Overhead costs were also included in the June 2025 shared direct cost calculation. Effect: The combined effect for these two months totaled $9,610 more in federal funding that could have been requested and drawn. Questioned Costs: There were no questioned costs identified. Cause: The errors resulted from inaccuracies in the shared direct cost calculation for May and June 2025. Management indicated that the calculation will be corrected beginning in the next grant year. Auditor Recommendation: We recommend that the Center strengthen its internal controls over the preparation and review of the shared direct cost allocation calculation to reduce the risk of similar errors occurring in the future. Organization Response: This error resulted from staff turnover and transition of the draw process to new accounting personnel. We will review the allocation of allowable costs and strengthen controls to ensure accurate cost accounting for future submissions. The error will be corrected in the August 2026 draw submission. The Controller and CFO are responsible for implementing and monitoring these corrective actions.

Activities Allowed or Unallowed Allowable Costs and Cost Principles U.S. Department of Public Health ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project Criteria: The funds are to be used primarily to support direct treatment services for individuals impacted by the COVID-19 pandemic. No more than 15 percent of the total grant award for each budget period may be used for data collection, performance measurement, and performance assessment, including incentives for participating in the required data collection follow-up. Up to $25,000 of the annual grant award for each budget period may be used to purchase technical assistance. If technical assistance is not needed, the recipient may use those funds for allowable or required activities. Condition: The Center was unable to provide support demonstrating the tracking and internal controls used to monitor the 15 percent requirement and the $25,000 technical assistance limit requirement. The Center supplied prepared financial statements for each quarter, which supported the amounts claimed as used with these funds. However, transaction detail of what made up these totals could not be provided. Context: There are two 12-month incremental periods in this award; the first restricts the recipient from spending more than $2,000,000 from 2/15/2021 to 2/14/2022, and the second period is also limited to $2,000,000 for the period covering 2/15/2022 to 2/14/2023. Staff prepared financial statements for each quarter that showed total income received and expenses incurred for the program. Effect: We were unable to determine if the Center complied with the 15 percent requirement or the $25,000 technical assistance limit. We were also unable to test a sample of direct costs charged to the program since transaction details supporting the prepared financial statements were not provided. Questioned Costs: We were unable to determine if there were any questioned costs. Cause: The Center has financial statements and spreadsheets showing what costs were attributable to this program, but we were not provided with information showing the tracking of these requirements or details of these costs. Staff responsible for tracking this information are no longer employed with the Center. Auditor Recommendation: We recommend that the Center implement procedures to adequately retain supporting documents for federal programs. Organization Response: The Staff Accountant will retain in hard copy and/or electronic form all supporting documentation of costs attributable to the CCBHC grant. Electronic records of grant transactions will be kept on CFMH one drive cloud, and printed copies will be kept in a grant folder. This includes but is not limited to all requests and approvals of expenditures, drawdowns, and any funding revisions and approvals. The supporting documents substantiating specific revenue and expense detail for the transactions will be uploaded and attached to the specific journal entry in Intacct. It will be the responsibility of the Accounting Manager (or Controller in the absence of the Accounting Manager) to monitor compliance with the retention of all supporting documentation by the Staff Accountant. The Accounting Manager (or Controller in the absence of the Accounting Manager) will be responsible for tracking and monitoring that no more than 15% of the total grant award for each budget period will be used for costs related to data collection, performance measurement, and performance assessment. The Accounting Manager (or Controller in the absence of the Accounting Manager) will also be responsible for tracking and monitoring that no more than $25,000 of the annual grant award for each budget period may be used for costs related to the purchase of technical assistance. The Center for Mental Health policies and procedures have been updated to include this additional level of accountability and internal control.

Cash Management U.S. Department of Public Health ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition: The Center has spreadsheets and financial statements supporting the amounts drawn during the year for this award; however, there was no indication that requests for reimbursements were reviewed or authorized prior to submission. Context: There were four draws made during the fiscal year for this award, totaling $2,410,670. For one draw, funds were drawn in advance of costs incurred, totaling $368,286. For the remaining three, funds were drawn on a reimbursement basis after costs were incurred. Effect: There is an increased risk of errors in draw amounts if internal controls are not in place. Questioned Costs: No questioned costs. Cause: Primarily, one staff member was responsible for the cash draws. Auditor Recommendation: We recommend that the Center establish policies and procedures for cash management over federal funds, implement internal controls over cash management, and retain documentation for these controls. Organization Response: Requests for cost reimbursements (drawdowns) from federal funds will be requested by the Accounting Manager (or Controller in the absence of the Accounting Manager) and reviewed and authorized by the Controller (or CFO in the absence of the Controller) prior to submission of the drawdown. Once the drawdown has been approved by the Controller (or CFO in the absence of the Controller), then the Accounting Manager submits the drawdown request for funds. In the absence of the Accounting Manager to submit the drawdown request, the Controller initiates the drawdown request, the CFO reviews and approves the request, and the Controller submits the drawdown request. Supporting documentation for cost reimbursement (drawdowns) will be maintained by the Controller (or CFO in the absence of the Controller) and the Staff Accountant and Accounting Manager will also retain any supporting documentation related to the drawdown of federal funds. The Center for Mental Health policy and procedure for cash management of federal funds has been updated to include this additional level of control.

Reporting U.S. Department of Public Health ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition: The Center completed programmatic reports as required in the grant award. However, there was no evidence that these reports were reviewed or authorized prior to submission. Context: There were two programmatic reports submitted during the audit period, and we tested one of the reports. Effect: There is an increased risk of errors or omissions in the programmatic reports. Questioned Costs: No questioned costs. Cause: Center staff stated the information was prepared by an employee and reviewed by another. However, no documentation was retained indicating the programmatic report was reviewed prior to submission. Auditor Recommendation: We recommend that the Center establish policies and procedures for reporting and retain documentation for these controls. Organization Response: The preparation of programmatic reports for federal funds will be the responsibility of the Staff Accountant. Any completed programmatic reports will then be reviewed by the Accounting Manager (or Controller in the absence of the Accounting Manager) and the grant Program Director (PD) and authorized by the Controller (or CFO in the absence of the Controller) prior to submission. Electronic and/or printed copies of written communications related to the review and approval of programmatic reports will be secured in a grant folder in the CFMH Microsoft Outlook email system and/or the Microsoft Teams application, or in a physical grants folder maintained by the Staff Accountant. The Controller (or CFO in the absence of the Controller) will have the responsibility to retain records pertaining to the communication demonstrating the review and approval of prepared programmatic reposts for federal grant funding. The Staff Accountant and the Accounting Manager will also retain any supporting documents related to communication of the review and approval process for programmatic reports for federal grant funding.

U.S. Department of Public Health Provider Relief Funds CFDA: 93.498 Criteria: Provider Relief Fund (PRF) reports are required to be submitted via the PRF reporting portal for recipients who have received one or more payments exceeding $10,000 in aggregate. Calculation of lost revenue attributable to the Coronavirus is a key line item in the report. There are three options to account for lost revenues. Option 1 was chosen by the Center, which is the difference between each years? actual patient care revenues. Actual revenue for 2019, 2020 and 2021, was used for each quarter during the period of availability. Condition: The PRF report submitted used calendar year 2019 information and 2020 fiscal year information for calculating lost revenue. Therefore, the same information for two quarters, covering July through December of 2019, was reported twice. The amounts used were not accurate for calculating lost revenue between 2019 and 2020. Context: Activity for July through December of 2018 was omitted from this calculation. Effect: The quarter comparisons for July through December 2019 showed no change in amounts. The calculation of lost revenue for that time frame is incorrect. A correction was made to the report, and the Center opted to report using Option 2, which is the difference between budgeted and actual patient care revenues. This corrected report was submitted in November 2021. Questioned Costs: There were no questioned costs identified. Cause: This was an error made when calculating the amounts for the lost revenue calculation. Recommendation: We recommend reports and supporting documentation for amounts included in the reports be reviewed prior to report issuance. Center Response: With the addition of a second professional accounting employee in early fiscal year 2022, the Center will have staff resources to be able to segregate the preparation of reports from the review of reports and supporting documentation prior to report issuance. Going forward, all reports will be subject to review prior to issuance by an accounting staff member other than the preparer.

U.S. Department of Public Health Provider Relief Funds CFDA: 93.498 Criteria: The Schedule of Expenditures of Federal Awards (SEFA) reporting amounts for this program are based upon the PRF report that is required to be submitted. The payments received for this program from April 1, 2020, to June 30, 2020, should be reported on the SEFA for the fiscal year ending June 30, 2021. Any payments received after June 30, 2020, will be reported on the SEFA for the fiscal year ending June 30, 2022. Condition: The SEFA provided included payments received after June 30, 2020. Context: The SEFA provided was overstated by $952,198. Effect: The amount reported on the SEFA provided was overstated. This has been corrected and the amount included in the report, $12,230, are payments received April 1, 2020 through June 30, 2020. Questioned Costs: There were no questioned costs identified. Cause: This was an error made when preparing the SEFA. Guidance changed for this program and old guidance was used. Recommendation: We recommend the SEFA be reviewed prior to finalization. Center Response: With the addition of a second professional accounting employee in early fiscal year 2022, the Center will have staff resources to be able to segregate the preparation of the SEFA report from the review of the SEFA and its supporting documentation prior to issuance. Going forward, all SEFA reports will be subject to review prior to issuance by an accounting staff member other than the preparer.