EIN: 910869056
UEI: T4PQLK8JNHL1
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 1, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 1, 2026 (66 days from today).
What is a management decision? →Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Non-Compliance) Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We selected a non-statistical sample of 60 patients who received services during the audit period, out of a population of approximately 5,300 patients, and noted the Health Board did not maintain Tribal enrollment documentation for 1 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is a repeat finding from the prior year. See prior year finding 2024-001. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Non-Compliance) Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We selected a non-statistical sample of 60 patients who received services during the audit period, out of a population of approximately 5,300 patients, and noted the Health Board did not maintain Tribal enrollment documentation for 1 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is a repeat finding from the prior year. See prior year finding 2024-001. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requirements, specifically related to documentation of Tribal enrollment. While prior corrective actions established foundational training and audit processes, management has identified the need for stronger front-end controls, clearer accountability, and system-based safeguards to prevent recurrence. Seattle Indian Health Board will implement the following actions: 1. Strengthen Front-End Eligibility Controls - Eligibility verification protocols will be updated to require complete Tribal enrollment documentation prior to scheduling non-urgent appointments. - A standardized eligibility checklist will be embedded into intake workflows to ensure all required documentation is identified and collected before services are rendered. 2. System Enhancement and Documentation Tracking - Electronic health record workflows will be enhanced to include required fields and alters for missing eligibility documentation, including Tribal enrollment. - Patients with incomplete eligibility records will be flagged, and services will be limited to allowable scenarios until documentation is obtained. 3. Targeted Training and Competency Validation - All registration and front desk staff will undergo mandatory retraining focused specifically on Tribal enrollment documentation requirements and compliance standards. - Staff competency will be validated through post-training assessments and periodic spot checks. 4. Enhanced Monitoring and Internal Audit - Monthly eligibility audits will be expanded to include a statistically valid sample size and documented review of Tribal enrollment verification. - Audit results will be formally reported to executive leadership, with identified deficiencies tracked through resolution. - Repeat errors or noncompliance will be addressed through corrective coaching and performance management, as appropriate. Management believes these enhanced corrective actions directly address the root cause of the finding by strengthening preventive controls, improving staff competency, and increasing oversight and accountability. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.
2024-001
Finding 2025-002 – Suspension and Debarment (Significant Deficiency in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions more than $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies identified in the suspension and debarment process, include the following: • The program had 18 covered transactions over $25,000. From this full population, we randomly selected a sample of four covered transactions subject to suspension and debarment requirements. For one of the items tested the Health Board could not provide the required evidence that they performed a suspension and debarment search. For all of the items tested the Health Board could not provide the required evidence that there was a bid process or sole source justification used to select the vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is a repeat finding. See prior year finding 2024-002. Recommendation – The Health Board has adequate policies in place, so we recommend that departments overseeing programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Finding 2025-002 – Suspension and Debarment (Significant Deficiency in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions more than $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies identified in the suspension and debarment process, include the following: • The program had 18 covered transactions over $25,000. From this full population, we randomly selected a sample of four covered transactions subject to suspension and debarment requirements. For one of the items tested the Health Board could not provide the required evidence that they performed a suspension and debarment search. For all of the items tested the Health Board could not provide the required evidence that there was a bid process or sole source justification used to select the vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is a repeat finding. See prior year finding 2024-002. Recommendation – The Health Board has adequate policies in place, so we recommend that departments overseeing programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Finding 2025-002 – Suspension & Debarment (Significant Deficiency in Internal Control Over Compliance) Planned Corrective Action: Following the prior year’s audit, Finance completed a full review of all vendors exceeding the threshold in 2024 and obtained the required documentation. The vendor identified in 2025 was not included in that review because it did not exceed the threshold in 2024. The actions above are designed to ensure vendors are captured based on current-year activity. Seattle Indian Health Board will implement the following specific actions to ensure compliance with Uniform Guidance requirements: - Require a documented SAM.gov suspension and debarment check for all vendors prior to contract execution and once cumulative spending limits exceeds $25,000, regardless of prior year activity. - Require completion and retention of either a competitive bid summary or a written sole source justification for all covered transactions. - Perform a quarterly review of vendors with spend over $25,000 to confirm documentation is complete. Name of Responsible Party: Brian Jonas, Controller Anticipated Completion Date: September 30, 2026
2024-002
Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Criteria – In accordance with the Health and Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount scheduled so that amounts owed for health center services by eligible patients are adjusted based on the patients’ ability to pay. Condition and Context – We selected 40 patient visits out of the entire population of patients who may be eligible to receive benefits under the program during the fiscal year ended September 30, 2025. The Health Board did not retain underlying data in accordance with policy to support the sliding fee scale discount based on the patients’ family size or income. Additionally, the Health Board had instances in which discounts were not applied accurately based on the underlying support that was provided by the patient. In 6 out of the 40 samples tested, the Health Board was unable to locate underlying support required per their policy. Cause – The program did not follow the Health Board’s established policies to appropriately apply the sliding fee discounts under Uniform Guidance. Effect – Certain patients may have been billed amounts less than the amounts defined by the sliding fee discount schedule. Questioned Costs – Not applicable. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that further processes and training be put in place to ensure that the sliding fee scale is accurately applied to all qualifying program participants. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Criteria – In accordance with the Health and Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount scheduled so that amounts owed for health center services by eligible patients are adjusted based on the patients’ ability to pay. Condition and Context – We selected 40 patient visits out of the entire population of patients who may be eligible to receive benefits under the program during the fiscal year ended September 30, 2025. The Health Board did not retain underlying data in accordance with policy to support the sliding fee scale discount based on the patients’ family size or income. Additionally, the Health Board had instances in which discounts were not applied accurately based on the underlying support that was provided by the patient. In 6 out of the 40 samples tested, the Health Board was unable to locate underlying support required per their policy. Cause – The program did not follow the Health Board’s established policies to appropriately apply the sliding fee discounts under Uniform Guidance. Effect – Certain patients may have been billed amounts less than the amounts defined by the sliding fee discount schedule. Questioned Costs – Not applicable. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that further processes and training be put in place to ensure that the sliding fee scale is accurately applied to all qualifying program participants. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.
Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Update: Configure EPIC to automatically assign the appropriate sliding fee discount level to patients with zero income to ensure consistent application of the discount schedule. - Required Income Documentation at Intake: Update procedures to require front desk staff to record a patient’s income level at intake for all patients, including a reasonable estimate when documentation in unavailable. This is required for both an accurate sliding fee application and UDS reporting. - Standardized Documentation Requirements: Require retention of supporting documentation for income and family size in the patient record, or documented attestation when estimates are used, in accordance with policy. - Front Desk Training and Accountability: Provide targeted training to front desk and registration staff on sliding fee discount program requirements, with emphasis on proper data entry, documentation standards, and discount application. - Ongoing Monitoring: Implement monthly reviews of a sample of patient accounts to confirm sliding fee discounts are supported, accurately applied, and properly documented. Errors will be corrected and addressed with the staff as needed. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.
FAC accepted this audit on May 28, 2025 — management decision was due November 28, 2025.
Eligibility (Significant Deficiency in Internal Control Over Compliance and an Instance of Non-Compliance) Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We randomly selected 60 patients who received services during the audit period and noted the Health Board did not maintain Tribal enrollment documentation for 1 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is a repeat finding from the prior year. See prior year finding 2023-002. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Eligibility (Significant Deficiency in Internal Control Over Compliance and an Instance of Non-Compliance) Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We randomly selected 60 patients who received services during the audit period and noted the Health Board did not maintain Tribal enrollment documentation for 1 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is a repeat finding from the prior year. See prior year finding 2023-002. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Planned Corrective Action: The Seattle Indian Health Board has adopted a sliding fee program that provides discounts to eligible patients and Indian tribes. To address the auditors' concerns and further strengthen our internal controls, we are implementing a comprehensive corrective action plan. Firstly, we will ensure that all personnel involved in eligibility checks, including front desk staff and benefits specialists, are fully trained and aware of federal regulations and internal policies. This will be achieved through comprehensive training sessions and the development of a detailed training manual outlining eligibility criteria, documentation requirements, and procedural steps. Periodic refresher training sessions will reinforce adherence to these policies. Secondly, we will establish a robust internal audit system to regularly review and verify compliance with eligibility requirements. This includes integrating a monthly audit of eligibility determinations into the month-end reporting process, conducted by the clinical operations team. The clinical operations team will use a standardized checklist during these audits to ensure consistency and thoroughness. They will document findings and follow up on any issues or discrepancies with the relevant personnel to ensure timely corrections and adherence to procedures. Management believes that we have adequate internal control systems to safeguard the organization's assets and comply with federal and local regulations. However, we remain committed to further strengthening our controls and processes where necessary. Name of Responsible Party: Mary Kelley, Director of Revenue Cycle Anticipated Completion Date: September 30, 2025
2023-002
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Planned Corrective Action: It is the policy of the Seattle Indian Health Board to retain documentation that a new vendor is not debarred from doing business with the federal government. In certain circumstances, due to the age of the vendor or other reasons, the documentation was not maintained. Management has engaged the accounts payable team to perform a review of all vendors accounts to assure all required documentation is on file and to continue this review on an annual basis. Name of Responsible Party: Brian Jonas., Controller Anticipated Completion Date: September 30, 2025
FAC accepted this audit on June 18, 2024 — management decision was due December 18, 2024.
Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We randomly selected 60 patients who received services during the audit period and noted the Health Board did not maintain Tribal enrollment documentation for 2 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management respectfully disagrees with the characterization of the finding as a material weakness in internal control over compliance and material noncompliance. A sliding fee program was adopted that provides discounts to eligible patients and Indian tribes. A guideline was implemented to serve those who are federally eligible with documentation to support the assertions for eligibility and approval of the discount consideration. Staff are well-trained and are aware of the federal regulation that the Health Board will adhere to it and it is included in the policy. Considering a 3% error of the sample (2 out of 60) outcome of the audit, the Health Board feels it is immaterial. Management believes that there is adequate internal control that will safe guard the assets of the organization and comply with federal and local government regulations. While the expertise of the audit team is valued and insights are appreciated, the Health Board believes that labeling this finding as a material weakness does not accurately reflect the overall strength and effectiveness of the internal control over compliance.
Show full finding ▾Hide full finding ▴Criteria – In accordance with the Health Board’s grant award with the Portland Area Indian Health Service, Indian Health Service eligibility regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition and Context – The Health Board is required to maintain eligibility records for patients who receive services under the Urban Indian Health Services program. These records include Tribal enrollment and insurance coverage, among other things. We randomly selected 60 patients who received services during the audit period and noted the Health Board did not maintain Tribal enrollment documentation for 2 of the 60 patients tested. Cause – The Health Board staff did not appear to be sufficiently trained to properly identify tribal enrollment documentation and ensure all required documents were obtained prior to providing services. Effect – Individuals that are not eligible may have received services. Questioned Costs – Questioned costs associated with this finding could not be determined. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the Health Board update polices and controls to include regular review of patient files. This may include review of the patient file for any outstanding Tribal enrollment and insurance documentation prior to scheduling the patients’ appointment. Views of responsible officials – Management respectfully disagrees with the characterization of the finding as a material weakness in internal control over compliance and material noncompliance. A sliding fee program was adopted that provides discounts to eligible patients and Indian tribes. A guideline was implemented to serve those who are federally eligible with documentation to support the assertions for eligibility and approval of the discount consideration. Staff are well-trained and are aware of the federal regulation that the Health Board will adhere to it and it is included in the policy. Considering a 3% error of the sample (2 out of 60) outcome of the audit, the Health Board feels it is immaterial. Management believes that there is adequate internal control that will safe guard the assets of the organization and comply with federal and local government regulations. While the expertise of the audit team is valued and insights are appreciated, the Health Board believes that labeling this finding as a material weakness does not accurately reflect the overall strength and effectiveness of the internal control over compliance.
Planned Corrective Action: The Seattle Indian Health Board has adopted a sliding fee program that provides discounts to eligible patients and Indian tribes. To address the auditors' concerns and further strengthen our internal controls, we are implementing a comprehensive corrective action plan. Firstly, we will ensure that all personnel involved in eligibility checks, including front desk staff and benefits specialists, are fully trained and aware of federal regulations and internal policies. This will be achieved through comprehensive training sessions and the development of a detailed training manual outlining eligibility criteria, documentation requirements, and procedural steps. Periodic refresher training sessions will reinforce adherence to these policies. Secondly, we will establish a robust internal audit system to regularly review and verify compliance with eligibility requirements. This includes integrating a monthly audit of eligibility determinations into the month-end reporting process, conducted by the clinical operations team. The clinical operations team will use a standardized checklist during these audits to ensure consistency and thoroughness. They will document findings and follow up on any issues or discrepancies with the relevant personnel to ensure timely corrections and adherence to procedures. Management believes that we have adequate internal control systems to safeguard the organization's assets and comply with federal and local regulations. However, we remain committed to further strengthening our controls and processes where necessary. Name of Responsible Party: Zecharias Mesgane, CMA, Director of FP&A Anticipated Completion Date: September 30, 2024
Criteria – Federal regulations and grant terms and conditions of the programs require annual fiscal reports be submitted to the awarding agencies. In accordance with Uniform Guidance 2 CFR 200.303 the Health Board should have internal controls established to ensure accuracy of information reported and ensure compliance with reporting requirements. Additionally, good internal controls require that an individual who did not prepare the report should review the report for accuracy prior to submission. Condition and Context – The annual SF-425 reports required under each program were submitted, but we noted no evidence of secondary review by an individual other than the preparer. As a result, the submitted SF-425 reports misreported total program expenditures for the period and the reports were ultimately rejected by the funding agencies causing the Health Board’s accounting department to correct and re-submit SF-425 reports subsequent to the period under audit. Cause – The Health Board does not have sufficient internal controls over their grant reporting process to ensure proper review of report prior to submission to ensure all reported information is accurate. Effect – There is an increased likelihood of errors in the information reported to federal agencies and ultimately an increased likelihood of noncompliance over reporting requirements. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the Health Board improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Show full finding ▾Hide full finding ▴Criteria – Federal regulations and grant terms and conditions of the programs require annual fiscal reports be submitted to the awarding agencies. In accordance with Uniform Guidance 2 CFR 200.303 the Health Board should have internal controls established to ensure accuracy of information reported and ensure compliance with reporting requirements. Additionally, good internal controls require that an individual who did not prepare the report should review the report for accuracy prior to submission. Condition and Context – The annual SF-425 reports required under each program were submitted, but we noted no evidence of secondary review by an individual other than the preparer. As a result, the submitted SF-425 reports misreported total program expenditures for the period and the reports were ultimately rejected by the funding agencies causing the Health Board’s accounting department to correct and re-submit SF-425 reports subsequent to the period under audit. Cause – The Health Board does not have sufficient internal controls over their grant reporting process to ensure proper review of report prior to submission to ensure all reported information is accurate. Effect – There is an increased likelihood of errors in the information reported to federal agencies and ultimately an increased likelihood of noncompliance over reporting requirements. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – We recommend the Health Board improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Planned Corrective Action: To address a gap identified internally by the Health Board, a new, comprehensive reconciliation and reporting process has been established. This gap was recognized when new finance department leadership assumed their positions prior to audit fieldwork, leading to the development and implementation of immediate corrective actions. Management at the Health Board has implemented a robust internal control process that includes reconciliation in two phases, which was developed in collaboration with our grants team. This documented process ensures thorough reconciliation and robust internal controls. It enhances the accuracy and timeliness of our financial reporting, particularly for FFR SF-425 submissions, thereby strengthening our overall financial management practices. The following outlines the detailed steps of this process, divided into two critical phases: Phase I: Revenue, Expenses, and Cash Reconciliation 1. Reconciliation by FP&A Analyst: Ensures that the figures and documents entered in Sage Intacct align with the Payment Management System (PMS) regarding authorized grant amounts and drawdown amounts at each month-end close. 2. Grant Receivable Invoices: Recorded in Sage Intacct as part of the month-end close process. A billing or AR accountant collects the expenses and enters corresponding revenue amounts, which the system uses to generate invoices. 3. Notification of Drawdown: The FP&A Analyst notifies the Director of FP&A and the Account Manager via email about the drawdown and the corresponding invoice amount. 4. Verification and Processing: The Director of FP&A verifies the amount and processes the drawdown from PMS to the bank. 5. Monthly CFO Report: The CFO receives a monthly status report. Phase II: FFR Reporting 1. Weekly PMS Review: Every Monday, the PMS is reviewed to identify any projects pending or expired for quarterly, annual, and final report periods. 2. Preparation of Revenue Reports: The billing or AR accountant prepares the direct and indirect revenue based on expense amounts. 3. Submission for Approval: The prepared revenue reports are submitted in the PMS for approval by the Director of FP&A. 4. Final Submission: After the DFPA's approval and final submission in the PMS, the information appears in the Grant Solution system for further approval by the program and grants team. 5. PMS Report: Receive an approval or rejection report from the PMS. Name of Responsible Party: Zecharias Mesgane, CMA, Director of FP&A Anticipated Completion Date: September 30, 2024
Criteria – Federally funded entities must establish internal control procedures over compliance with provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) that require, among other things, that direct charges to federal awards be for allowable costs. To be an allowable cost, charges must be supported by appropriate documentation and be properly approved. Condition and Context – Employee payroll costs are charged to programs based on an approved timesheet, and an allocation rate and pay rate approved through each employee’s personnel action for action form. For pay periods spanning reporting periods the Health Board allocates employee payroll costs to each reporting period based on the number of days of each reporting period included in the pay period. The first payroll subsequent to year-end covered the period September 25, 2023 through October 8, 2023. This pay period included six days of fiscal year 2023 and eight days of fiscal year 2024. However, the Health Board incorrectly accrued eight days of payroll costs to fiscal year 2023, thereby overcharging the programs. Cause – It appears this deficiency was caused by inadequate internal controls over the year-end payroll accrual calculation. Effect – Without strong internal controls over payroll unallowable expenditures could be charged to a federally funded program. Questioned Costs – This control deficiency resulted in the following questioned costs; • AL Number 93.193 – Known questioned costs were $49,659 • AL Number 93.479 – Known questioned costs were $1,613 • AL Number 93.231 – Known questioned costs were $11,355 Since we evaluated 100% of the year-end accrued payroll there are no likely questioned costs. Repeat Finding – No Recommendation – We recommend the Health Board improve the controls over the payroll, to ensure year-end accrual amounts are properly calculated. Views of responsible officials – Management respectfully disagrees with the characterization of the finding as a significant deficiency in internal control over compliance and another matter. Management believes the internal control processes and reviews currently in place are effective. Management will implement the additional review step identified in the corrective action plan to further enhance the internal control.
Show full finding ▾Hide full finding ▴Criteria – Federally funded entities must establish internal control procedures over compliance with provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) that require, among other things, that direct charges to federal awards be for allowable costs. To be an allowable cost, charges must be supported by appropriate documentation and be properly approved. Condition and Context – Employee payroll costs are charged to programs based on an approved timesheet, and an allocation rate and pay rate approved through each employee’s personnel action for action form. For pay periods spanning reporting periods the Health Board allocates employee payroll costs to each reporting period based on the number of days of each reporting period included in the pay period. The first payroll subsequent to year-end covered the period September 25, 2023 through October 8, 2023. This pay period included six days of fiscal year 2023 and eight days of fiscal year 2024. However, the Health Board incorrectly accrued eight days of payroll costs to fiscal year 2023, thereby overcharging the programs. Cause – It appears this deficiency was caused by inadequate internal controls over the year-end payroll accrual calculation. Effect – Without strong internal controls over payroll unallowable expenditures could be charged to a federally funded program. Questioned Costs – This control deficiency resulted in the following questioned costs; • AL Number 93.193 – Known questioned costs were $49,659 • AL Number 93.479 – Known questioned costs were $1,613 • AL Number 93.231 – Known questioned costs were $11,355 Since we evaluated 100% of the year-end accrued payroll there are no likely questioned costs. Repeat Finding – No Recommendation – We recommend the Health Board improve the controls over the payroll, to ensure year-end accrual amounts are properly calculated. Views of responsible officials – Management respectfully disagrees with the characterization of the finding as a significant deficiency in internal control over compliance and another matter. Management believes the internal control processes and reviews currently in place are effective. Management will implement the additional review step identified in the corrective action plan to further enhance the internal control.
Planned Corrective Action: Management of the Health Board have placed appropriate measures to oversee the internal control process of the month and year-end close. The accounting staff will prepare the transactions and the controller will approve it accordingly and the Director of FP&A will rectify them whenever FFR reports are completed. We have implemented strong internal control by separating the preparation of the month and year end reporting to be done by staff accountant and approved by Controller or Director of FPA. In addition, the CFO is reviewing month-end reconciliations on a quarterly basis. Name of Responsible Party: Zecharias Mesgane, CMA, Director of FP&A Anticipated Completion Date: September 30, 2024.
FAC accepted this audit on June 29, 2023 — management decision was due December 29, 2023.
Documentation that a household met the eligibility requirements of the program was unable to be located for 9 of the 28 payments selected for testing. Questioned Costs: Of the 10 households that were found to be unsupported by sufficient documentation of eligibility benefit payments totaling approximately $90,000 were processed. Extrapolation of the error rate calculated based upon the testing performed resulted in an estimated error of approximately $582,000 of potentially unsupported benefit payments in the remaining untested benefit payments. Context: The terms of the contract required documentation of household eligibility for benefits. Due to turnover of grant staff a number of records are unable to be located. Cause: Insufficient internal control processes and procedures to retain documentation that support determinations for eligibility of grant recipients to receive benefit under a federal award program. Effect: The Health Board awarded benefits to recipients that may not have been eligible under the contract requirements. Recommendation: The Health Board should ensure that program managers are aware of the significant compliance requirements of an award and implement a system of internal control that supports compliance and documentation of compliance.
Show full finding ▾Hide full finding ▴Finding 2022-002 Eligibility Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Program Assistance Listing Number: 21.027 Award Period: 9/1/2021 ? 6/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or specific requirement: Eligibility requirements under contract 21-4619C-201 Eviction Rent Assistance Program 2.0 with the Washington State Department of Commerce require households to meet the criteria of income at or below 80% of Area Median Income and have missed or past due rent payment not paid or partially unpaid since March 1, 2020 and still be occupying the residence. Condition: Documentation that a household met the eligibility requirements of the program was unable to be located for 9 of the 28 payments selected for testing. Questioned Costs: Of the 10 households that were found to be unsupported by sufficient documentation of eligibility benefit payments totaling approximately $90,000 were processed. Extrapolation of the error rate calculated based upon the testing performed resulted in an estimated error of approximately $582,000 of potentially unsupported benefit payments in the remaining untested benefit payments. Context: The terms of the contract required documentation of household eligibility for benefits. Due to turnover of grant staff a number of records are unable to be located. Cause: Insufficient internal control processes and procedures to retain documentation that support determinations for eligibility of grant recipients to receive benefit under a federal award program. Effect: The Health Board awarded benefits to recipients that may not have been eligible under the contract requirements. Recommendation: The Health Board should ensure that program managers are aware of the significant compliance requirements of an award and implement a system of internal control that supports compliance and documentation of compliance.
U.S. DEPARTMENT OF TREASURY 2022-002 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: The Health Board should ensure that program managers are aware of the significant compliance requirements of an award and implement a system of internal control that supports compliance and documentation of compliance. Explanation of disagreement with audit finding: We respectfully disagree with the characterization of the finding as a material weakness in internal control. The sample size of 28 selections called for 3 specific source documents to be provided in association with each sample. Thus, 10 out of a total of 84 source documents requested were not immediately available. The eligibility forms in question are part of the process which initiates the determination of the validity of the request for assistance. Due to the sensitive nature of this program, these documents are not readily available electronically (in order to protect the privacy of the recipients). The Health Board?s Community Services Team, which includes Rapid Rehousing, Gender-Based Violence, and Emergency Housing, experienced significant turnover due to the pandemic. We have informed the auditor about the turnover challenges faced by this specific department and the difficulties in securing physical documentation. Action taken in response to finding: In September 2022, the Community Service Team began reporting to the Health Board?s Behavioral Health Officer. Under her direction, processes have been updated and documented along with the creation of a stronger review process. The health board remains committed to further strengthening our controls and processes where necessary. We will ensure that program managers are aware of the compliance requirements associated with the award and implement a robust system of internal control that supports compliance and proper documentation. Name(s) of the contact person(s) responsible for corrective action: Linda Zhang, CFO Planned completion date for corrective action plan: September 30, 2023 If the U.S. Department of Treasury has questions regarding this plan, please call Linda Zhang, CFO at (206) 324-9360.
FAC accepted this audit on July 6, 2022 — management decision was due January 6, 2023.
The Health Board?s sliding fee program provides discounts to eligible patients based upon income and household size as compared to federal poverty levels. Patients were provided a sliding fee discount that was inappropriate or incorrect. The Health Board also did not maintain documentation to support the determination of eligibility or approval of the discount. Questioned Costs: None Context: A sample of 40 sliding fee encounters were selected for testing. Of the sample tested, there were three encounters for which the applicable slide level had been incorrectly determined based on the patient's household and income information. Additionally, there was one patient encounter for which the sliding fee application could not be located. Similar errors were identified in the prior year audit, and due to the timing of the prior year audit management was not able to implement corrective actions until the end of the current fiscal year. Cause: Incorrect calculation of sliding fee level and insufficient documentation of sliding fee determination. Effect: Improper sliding fee discounts were provided to patients. Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate that the slide calculation is accurate based on the information provided by the patient. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Finding 2021-001 Sliding Fee Discount Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Program Assistance Listing Numbers: 93.224 and 93.527 Award Periods: 2/1/2020 ? 1/31/2021, 2/1/2021 ? 1/31/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f)). Condition: The Health Board?s sliding fee program provides discounts to eligible patients based upon income and household size as compared to federal poverty levels. Patients were provided a sliding fee discount that was inappropriate or incorrect. The Health Board also did not maintain documentation to support the determination of eligibility or approval of the discount. Questioned Costs: None Context: A sample of 40 sliding fee encounters were selected for testing. Of the sample tested, there were three encounters for which the applicable slide level had been incorrectly determined based on the patient's household and income information. Additionally, there was one patient encounter for which the sliding fee application could not be located. Similar errors were identified in the prior year audit, and due to the timing of the prior year audit management was not able to implement corrective actions until the end of the current fiscal year. Cause: Incorrect calculation of sliding fee level and insufficient documentation of sliding fee determination. Effect: Improper sliding fee discounts were provided to patients. Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate that the slide calculation is accurate based on the information provided by the patient. Views of responsible officials: There is no disagreement with the audit finding.
Health Center Program Cluster ? CFDA No. 93.224 and 93.527 Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate review and approval of the application and assigned sliding fee classification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was initially identified during the prior year audit. During the year ended September 30, 2021, Seattle Indian Health Board has implemented additional training and compliance education to reception personnel and has assigned specific staff in the billing department to periodically review sliding fee patients? applications and proof of income to ensure they are appropriately classified according to federal poverty levels. Name(s) of the contact person(s) responsible for corrective action: Esther Lucero, CEO Planned completion date for corrective action plan: September 30, 2021
2020-001
Amendment 1 to contract C20-151 states that a final narrative and expense report will be due no later than October 15, 2021; however, the final report was submitted in January 2022 and did not include the expense report. Questioned Costs: None Context: The terms of the original grant agreement state that the final 10% of award funds will be paid upon submittal of the final report. As the Health Board did not incur sufficient program expenses and did not plan to request disbursement of the remaining 10%, there was some confusion as to whether the final report was required. However, the contract amendment dated June 29, 2021, explicitly gives a specific deadline for the final narrative and expense report and separately states that the remaining 10% of the award will be disbursed upon receipt and certification of the final report. Cause: Insufficient awareness of federal award reporting requirements and deadlines. Effect: The Health Board submitted the final report more than three months after the stated deadline and did not include the expense report. Recommendation: The Health Board should ensure that program managers compare all program reports to the reporting requirements within the grant documents to ensure all quantitative and qualitative information is appropriately included prior to submittal to the oversight agency. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Finding 2021-003 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement Program Assistance Listing Number: 93.772 Award Period: 7/9/2020 ? 8/30/2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Reporting requirements under contract C20-151 with the Northwest Portland Area Indian Health Board (NPAIHB). Condition: Amendment 1 to contract C20-151 states that a final narrative and expense report will be due no later than October 15, 2021; however, the final report was submitted in January 2022 and did not include the expense report. Questioned Costs: None Context: The terms of the original grant agreement state that the final 10% of award funds will be paid upon submittal of the final report. As the Health Board did not incur sufficient program expenses and did not plan to request disbursement of the remaining 10%, there was some confusion as to whether the final report was required. However, the contract amendment dated June 29, 2021, explicitly gives a specific deadline for the final narrative and expense report and separately states that the remaining 10% of the award will be disbursed upon receipt and certification of the final report. Cause: Insufficient awareness of federal award reporting requirements and deadlines. Effect: The Health Board submitted the final report more than three months after the stated deadline and did not include the expense report. Recommendation: The Health Board should ensure that program managers compare all program reports to the reporting requirements within the grant documents to ensure all quantitative and qualitative information is appropriately included prior to submittal to the oversight agency. Views of responsible officials: There is no disagreement with the audit finding.
Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? CFDA No. 93.772 Recommendation: The Health Board should ensure that program managers compare all program reports to the reporting requirements within the grant documents to ensure all quantitative and qualitative information is appropriately included prior to submittal to the oversight agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Health Board will provide additional training to program staff to ensure reporting requirements are met and will implement calendar reminders and other tools to ensure reports are submitted timely. Name(s) of the contact person(s) responsible for corrective action: Esther Lucero, CEO Planned completion date for corrective action plan: September 30, 2022
The auditor tested a sample of three transactions from a population of twelve transactions for which the financial obligation incurred under the federal award had not been paid as of the end of the period of performance. One exception was identified where payment of the obligation occurred more than 120 days after the end of the period of performance of the program. Questioned Costs: None Context: Due to various contract amendments and the ongoing nature of the services with this vendor, payment for services rendered during the federal award period was not made until more than 120 days after the end of the period of performance. Cause: Internal process and procedures did not incorporate both a timeline for grant closure and adequate time to adhere to the Health Board?s internal control requirements. Effect: The federal award closeout process did not occur timely, which resulted in delayed payment of grant expenditures. Recommendation: The Health Board should ensure that the closeout process for all federal award programs is completed within 120 days of the end of the period of performance and that all financial obligations incurred under federal awards are liquidated as part of this process. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Finding 2021-004 Grant Close Out Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement Program Assistance Listing Number: 93.772 Award Period: 7/9/2020 ? 8/30/2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 2 CFR section 200.344(b). Condition: The auditor tested a sample of three transactions from a population of twelve transactions for which the financial obligation incurred under the federal award had not been paid as of the end of the period of performance. One exception was identified where payment of the obligation occurred more than 120 days after the end of the period of performance of the program. Questioned Costs: None Context: Due to various contract amendments and the ongoing nature of the services with this vendor, payment for services rendered during the federal award period was not made until more than 120 days after the end of the period of performance. Cause: Internal process and procedures did not incorporate both a timeline for grant closure and adequate time to adhere to the Health Board?s internal control requirements. Effect: The federal award closeout process did not occur timely, which resulted in delayed payment of grant expenditures. Recommendation: The Health Board should ensure that the closeout process for all federal award programs is completed within 120 days of the end of the period of performance and that all financial obligations incurred under federal awards are liquidated as part of this process. Views of responsible officials: There is no disagreement with the audit finding.
Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? CFDA No. 93.772 Recommendation: The Health Board should ensure that the closeout process for all federal award programs is completed within 120 days of the end of the period of performance and that all financial obligations incurred under federal awards are liquidated as part of this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Health Board will implement a formal grant closeout process for all federal awards, and as part of this process, will ensure all outstanding financial obligations incurred through federal programs are liquidated within the allowable period. Name(s) of the contact person(s) responsible for corrective action: Esther Lucero, CEO Planned completion date for corrective action plan: September 30, 2022
FAC accepted this audit on June 8, 2021 — management decision was due December 8, 2021.
The Health Board?s sliding fee program provides discounts to eligible patients based upon income and household size as compared to federal poverty levels. Patients were provided a sliding fee discount that was inappropriate or incorrect. The Health Board also did not maintain documentation to support the determination of eligibility or approval of the discount. Questioned Costs: None Context: A sample of 40 sliding fee encounters were selected for testing. Of the sample tested, 18 of 40 items did not have supporting documentation of review and approval of the sliding fee discount assigned. Additionally, no documentation of income or household size was available for two of the selections, and there were three instances identified where an incorrect adjustment was applied. Cause: Insufficient documentation of sliding fee determination, approval, and eligibility. Effect: Improper sliding fee discounts were provided to patients. Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate review and approval of the application and assigned sliding fee classification. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Finding 2020-001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Program CFDA Numbers: 93.224 and 93.527 Award Period: 2/1/2020-1/31/2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Criteria or Specific Requirement ? Special Tests and Provisions: Sliding Fee Discounts (42 USC 254(k)(3)(g); 42 CFR section 51c.303(g) and 42 CFR section 56.303(f)). Condition: The Health Board?s sliding fee program provides discounts to eligible patients based upon income and household size as compared to federal poverty levels. Patients were provided a sliding fee discount that was inappropriate or incorrect. The Health Board also did not maintain documentation to support the determination of eligibility or approval of the discount. Questioned Costs: None Context: A sample of 40 sliding fee encounters were selected for testing. Of the sample tested, 18 of 40 items did not have supporting documentation of review and approval of the sliding fee discount assigned. Additionally, no documentation of income or household size was available for two of the selections, and there were three instances identified where an incorrect adjustment was applied. Cause: Insufficient documentation of sliding fee determination, approval, and eligibility. Effect: Improper sliding fee discounts were provided to patients. Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate review and approval of the application and assigned sliding fee classification. Views of responsible officials: There is no disagreement with the audit finding.
2020-001 Health Center Program Cluster ? CFDA No. 93.224 and 93.527 Recommendation: The Health Board should maintain sufficient records of all patients' sliding fee determination documents and have an appropriate staff member sign these documents to indicate review and approval of the application and assigned sliding fee classification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Seattle Indian Health Board has implemented additional training and compliance education to reception personnel and has assigned specific staff in the billing department to periodically review sliding fee patients? applications and proof of income to ensure they are appropriately classified according to federal poverty levels. Planned completion date for corrective action plan: September 30, 2021
Per the Health Board?s indirect cost rate agreement the base on which indirect cost is calculated should exclude capital expenditures. The Health Board failed to exclude a capital cost in its calculation of indirect cost for reimbursement by the grant. Questioned Cost: $58,856 Context: A sample of five drawdowns were selected for testing. Of the sample tested, one of the selections included a capital expenditure in the calculation of indirect cost. Cause: Insufficient awareness of the cost requirements by staff performing the calculation of indirect costs during the grant invoicing process. Effect: The Health Board received reimbursement of indirect cost over and above what it was entitled to. Recommendation: The Health Board should provide additional training and education for personnel involved in the calculation, review, and approval process of expenses to be reimbursed by federal grants. Views of responsible officials: There is no disagreement with the audit finding 2020-002.
Show full finding ▾Hide full finding ▴Finding 2020-002 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Program CFDA Numbers: 93.224 and 93.527 Award Period: 2/1/2020-1/31/2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Criteria or specific requirement: Criteria or Specific Requirement ? Allocable Costs CFR section 75.413 and 75.414. Condition: Per the Health Board?s indirect cost rate agreement the base on which indirect cost is calculated should exclude capital expenditures. The Health Board failed to exclude a capital cost in its calculation of indirect cost for reimbursement by the grant. Questioned Cost: $58,856 Context: A sample of five drawdowns were selected for testing. Of the sample tested, one of the selections included a capital expenditure in the calculation of indirect cost. Cause: Insufficient awareness of the cost requirements by staff performing the calculation of indirect costs during the grant invoicing process. Effect: The Health Board received reimbursement of indirect cost over and above what it was entitled to. Recommendation: The Health Board should provide additional training and education for personnel involved in the calculation, review, and approval process of expenses to be reimbursed by federal grants. Views of responsible officials: There is no disagreement with the audit finding 2020-002.
2020-002 Health Center Program Cluster ? CFDA No. 93.224 and 93.527 Recommendation: The Health Board should provide additional training and education for personnel involved in the calculation, review, and approval process of indirect costs to be reimbursed by federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Seattle Indian Health Board has implemented additional levels of review by appropriate grants department staff for all grant invoices containing equipment purchases prior to being submitted for reimbursement, including recomputing the total indirect costs for the invoice and ensuring that only appropriate direct costs are included in the calculation. Planned completion date for corrective action plan: September 30, 2021
A non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurement policy conforms to applicable federal law and the standards identified in the general procurement standards. The Health Board did not follow its procurement policy. Questioned Costs: None Context: During the audit process it was noted that the Health Board failed to follow its documented procurement procedures for small purchases. Cause: Expediency of procurement resulted in variance from policy related to the solicitation of bids and documentation of process and approvals. Effect: Purchases may not adhere to the internal procurement policies of the Health Board and result in a purchase that is non-compliant. Recommendation: The Health Board should review their procurement policy and procedures and adopt processes that will provide more flexibility for the Health Board while maintaining compliance with federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding 2020-002.
Show full finding ▾Hide full finding ▴Finding 2020-003 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Good Health and Wellness in Indian Country and Epidemiology Cooperative Agreements Program CFDA Numbers: 93.479 and 93.231 Award Period: 9/30/2019-9/29/2020 and 9/30/2019 and 9/29/2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: Criteria or Specific Requirement ? Procurement 45 CFR Sections 75.327 through 75.329 Condition: A non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurement policy conforms to applicable federal law and the standards identified in the general procurement standards. The Health Board did not follow its procurement policy. Questioned Costs: None Context: During the audit process it was noted that the Health Board failed to follow its documented procurement procedures for small purchases. Cause: Expediency of procurement resulted in variance from policy related to the solicitation of bids and documentation of process and approvals. Effect: Purchases may not adhere to the internal procurement policies of the Health Board and result in a purchase that is non-compliant. Recommendation: The Health Board should review their procurement policy and procedures and adopt processes that will provide more flexibility for the Health Board while maintaining compliance with federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding 2020-002.
2020-003 Good Health and Wellness in Indian Country and Epidemiology Cooperative Agreements ? CFDA No. 93.479 and 93.231 Recommendation: The Health Board should review their procurement policy and procedures and adopt processes that will provide more flexibility for the Health Board while maintaining compliance with federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Executive leadership has drafted a new procurement policy that mirrors federal procurement requirements. This policy is currently awaiting final approval from the board of directors. Seattle Indian Health Board has also implemented additional training for all executive, divisional leadership teams (ELT, DLT) and leadership supporting team (LST), program, and finance, involved in procurement transactions. Planned completion date for corrective action plan: September 30, 2021
FAC accepted this audit on February 22, 2018 — management decision was due August 22, 2018.
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