Brevard Health Alliance, Inc.Non-Profit

2024 – 001 – Factors Affecting Allowability of Costs Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 2 CFR Part 200.403 sets forth the requirements for costs to be allowable. This section specifically states that costs should “not be included as a cost or used to meet cost sharing requirements of any other federally-financed program in either the current or a prior period.” 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: Brevard Health Alliance requested reimbursement for $8,978 of expenditures under two different federal grants. One grant is requested based upon clinic hours and another based on an individual’s time and effort. Cause: The cause of the situation was due to poorly designed internal control procedures related to the allocation of payroll expense requested for reimbursement between various grants. Effect: If the same expenditure is requested multiple times from the granting agency, they may request funds be returned. Questioned Cost: $8,978 of known questioned costs. However, the Alliance has additional allowable payroll costs to cover the amounts duplicated. Perspective: Total payroll that was requested for reimbursement was $5,251,473, with known questioned cost being $8,978 resulting in only 0.2% of payroll expenditures. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Management Response: Brevard Health Alliance will ensure allocation of payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

2024 – 002 – Special Test and Provisions Health Center Program & Grants for New and Expanded Services under the Health Center Program Assistance Listing Number: 93.224 & 93.527 Federal Award ID Number: H8004213 H8F41284 C1650401 H8G47667 H8L51683 H2E45573 Department of Health and Human Services Funding 2024 Criteria: 42 CFR sections 51c.303 (f) requires that Brevard Health Alliance “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 poverty guidelines updated periodically in the Federal Register by the U.S. Department of Health and Human Services under the authority of 42 U.S.C 9902(2); and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. 2 CFR 200.303 provides that non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. Condition: CRI selected a sample of 25 patients to ensure the sliding fee schedule was properly applied. 1 of the 25 patients had the incorrect fee scale applied. Cause: The cause appears to be human error by an employee selecting the incorrect sliding fee scale. Identifying every manual input error is difficult, however, the Alliance performs an audit of the sliding fee schedule for thousands of patients on an annual basis. Effect: Patients could be paying more or less than what is allowable based on the fee schedule. Questioned Cost: Undeterminable as the grant is not reimbursed based on patient fees. Perspective: The issue appears isolated as it was a 4% failure rate (1 out of 25). Recommendation: Procedures should be implemented to verify the sliding fee schedule applied to new patients.

2022-001 PROCUREMENT PROCEDURES COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For Homeless and Public Housing Primary Care) ? American Rescue Plan Act Assistance Listing Number: 93.224, Contract Numbers- H8F41284 Department of Health and Human Services (HHS) 2022 Funding Criteria: Pursuant to 2 CFR ?200.1, Simplified Acquisition Threshold (?SAT?), acquisitions which exceed the SAT of $250,000 must use one of the following procurement methods: the sealed bid method, the competitive proposals method, or the noncompetitive proposal method (sole source). Condition: The Alliance did not utilize the sealed bid method or competitive proposals method for a purchase of computer hardware, which exceeded the $250,000 SAT. The Alliance?s procurement policy was not updated to be in compliance 2 CFR 200.1 until April 2022. This purchase began in fiscal year 2021, but the remaining items under the contract were procured in fiscal year 2022. Cause: The Alliance?s policy only required bids for construction purchases, and not all purchases above the SAT. The expense for computer hardware exceeded the SAT of $250,000. The Controller believed the purchase met the qualification for a sole source purchase; however, the CIO did not document the purchase as a sole source purchase and reached out to another entity after the purchase to verify that no other vendor had the products with the required specifications. Effect: The purchase was not procured through a competitive practice, and therefore the purchase is a questioned cost. Questioned Costs: Known questioned costs is $291,982 for assistance listing 93.224. Perspective: The purchase made at the beginning of the year was procured under the old purchasing policy. The policy was updated in April 2022, and the additional purchase exceeding the bid threshold made subsequent to the new purchasing policy was procured under a competitive process. Recommendation: The Alliance should continue to follow its updated procurement policy. Management?s Response: Management has updated the procurement policy to comply with the provisions of 2 CFR ?200.1, 2 CFR ?200.67, and 2 CFR ?200.214. The updated policy has been implemented since this occurrence and will continue to be followed.

2021-001 PROCUREMENT PROCEDURES AND VENDOR DEBARMENT AND SUSPENSION PROCEDURES Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For Homeless and Public Housing Primary Care) ? American Rescue Plan Act Assistance Listing Number: 93.224, Contract Numbers- H8F41284, H8E38472, C1332037 Department of Health and Human Services (HHS) 2021 Funding Criteria: Pursuant to 2 CFR ?200.1, Simplified Acquisition Threshold (?SAT?), acquisitions which exceed the SAT of $250,000 must use one of the following procurement methods: the sealed bid method, the competitive proposals method, or the noncompetitive proposal method (sole source). Pursuant to 2 CFR ?200.214, non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. Pursuant to 2 CFR ?200.303(a) the Alliance is required to have controls in place to ensure proper compliance. Condition: The Alliance did not utilize the sealed bid method or competitive proposals method for a purchase of computer hardware which exceeded the $250,000 SAT. The Alliance?s procurement policy is not written in compliance with 2 CFR ?200.1 requirements. Also, the Alliance did not verify whether vendors were suspended or debarred for covered transactions. Cause: The Alliance?s policy only required bids for construction purchases, and not all purchases above the SAT. The expense for computer hardware exceeded the SAT of $250,000. The Controller believed the purchase met the qualification for a sole source purchase; however, the CIO did not document the purchase as a sole source purchase and did not reach out to multiple entities to verify that no other vendor had the products with the required specifications. Also, the Alliance did not have any policies or procedures in place. Effect: The purchase was not procured through a competitive practice, and therefore the purchase is a questioned cost. None of the vendors were verified by the Alliance for suspension or debarment; however, our tests of five vendors disclosed none of the vendors were suspended or debarred. Questioned Costs: Known questioned costs is $293,275 for assistance listing 93.224 Perspective: There was only one purchase during the year above the SAT. Recommendation: The Alliance?s procurement policy needs to be updated to comply with the provisions of 2 CFR ?200.1, 2 CFR ?200.67, and 2 CFR ?200.214, and procedures should be established to follow the updated policy. Management?s Response: Management will update the procurement policy to comply with the provisions of 2 CFR ?200.1, 2 CFR ?200.67, and 2 CFR ?200.214. The updated policy will be implemented and followed effective immediately.