Maniilaq Association

Finding 2025-001 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Health and Human Services Program Tribal Self-Governance Program: IHS Compacts/Funding Agreements Assistance Listing: No. 93.210 (Direct and pass-through Alaskan Native Tribal Health Consortium) Award No. 58G950028, 24-U-428002, 25-U-4599796 Year 2025, 2024, 2020, 2018, and 2019 Criteria or Specific Requirement In accordance with the IHS funding agreement requirements, as well as Uniform Guidance compliance requirements, the Association is required to maintain documentation of eligibility for the patients receiving medical assistance under the IHS program. Condition The Association was unable to provide proper documentation regarding eligibility of some of the patients for which their accounts were charged to the IHS compact. Cause The Association has multiple remote locations where there are challenges due to staffing and the Association has difficulty in obtaining eligibility information from older beneficiaries. Effect or Potential Effect Individuals may receive services funded by the IHS program who are ineligible to receive these benefits. Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For five of those patients, documentation proving eligibility was not on file. Identification as a Repeat Finding Was reported as finding 2024-001. Recommendation For all patients receiving services, verification of eligibility should be documented and kept on file electronically. If eligibility documentation is not provided, the hospital needs to attempt to collect on the outstanding balance from the individual or insurance companies, rather than charging as an IHS beneficiary. Views of Responsible Official and Planned Corrective Action Management agrees with finding. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance.

Finding 2024-001 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Health and Human Services Program Tribal Self-Governance Program: IHS Compacts/Funding Agreements Assistance Listing: No. 93.210 (Direct and pass-through Alaskan Native Tribal Health Consortium) Award No. 58G950028, 24-U-428002, AN 20-FG8, AN 18-HT5 and AN 19-HX3 Year 2024, 2020, 2018 and 2019 Criteria or Specific Requirement In accordance with the IHS funding agreement requirements, as well as Uniform Guidance compliance requirements, the Association is required to maintain documentation of eligibility for the patients receiving medical assistance under the IHS program. Condition The Association was unable to provide proper documentation regarding eligibility of some of the patients for which their accounts were adjusted to the IHS compact. Cause The Association is in the process of ensuring all the eligibility information is retained in the patient records. Effect or potential effect Individuals may receive services funded by the IHS program who are ineligible to receive these benefits. Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 2 of those patients, documentation proving eligibility was not on file. Identification as a repeat finding Was reported as finding 2023-001. Recommendation For all patients receiving services, verification of eligibility should be documented and kept on file electronically. If eligibility documentation is not provided, the hospital needs to attempt to collect on the outstanding balance from the individual or insurance companies, rather than adjusting as an IHS beneficiary. Views of Responsible Official and Planned Corrective Action Management agrees with finding. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance.

Finding 2023-001 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Health and Human Services Program Tribal Self-Governance Program: IHS Compacts/Funding Agreements Assistance Listing: No. 93.210 Award No. 58G950028 Year 2023 Criteria or Specific Requirement In accordance with the IHS funding agreement requirements, as well as Uniform Guidance compliance requirements, the Association is required to maintain documentation of eligibility for the patients receiving medical assistance under the IHS program. Condition The Association was unable to provide proper documentation regarding eligibility of some of the patients for which their accounts were adjusted to the IHS compact. Cause The Association is in the process of ensuring all the eligibility information is retained in the patient records. Effect or potential effect Individuals may receive services funded by the IHS program who are ineligible to receive these benefits. Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 5 of those patients, documentation proving eligibility was not on file. Identification as a repeat finding Was reported as finding 2022-003. Recommendation For all patients receiving services, verification of eligibility should be documented and kept on file electronically. If eligibility documentation is not provided, the hospital needs to attempt to collect on the outstanding balance from the individual or insurance companies, rather than adjusting as an IHS beneficiary. Views of Responsible Official and Planned Corrective Action Management agrees with finding. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance.

Finding 2022-003 Eligibility ? Noncompliance and Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Health and Human Services Program Tribal Self-Governance Program: IHS Compacts/Funding Agreements Assistance Listing: No. 93.210 Award No. 58G950028 Year 2022 Criteria or Specific Requirement In accordance with the IHS funding agreement requirements, as well as Uniform Guidance compliance requirements, the Association is required to maintain documentation of eligibility for the patients receiving medical assistance under the IHS program. Condition The Association was unable to provide proper documentation regarding eligibility of some of the patients for which their accounts were adjusted to the IHS compact. Cause COVID-19 pandemic disrupted established processes. Effect or potential effect Individuals may receive services funded by the IHS program who are ineligible to receive these benefits. Questioned Costs Unknown Context We tested 40 patients who were designated as IHS beneficiaries. For 8 of those patients documentation proving eligibility was not on file. Identification as a repeat finding Was reported as finding 2021-002. Recommendation For all patients receiving services, verification of eligibility should be documented and kept on file electronically. If eligibility documentation is not provided, the hospital needs to attempt to collect on the outstanding balance from the individual or insurance companies, rather than adjusting as an IHS beneficiary. Views of Responsible Official and Planned Corrective Action Management agrees with finding. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance.

Finding 2022-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles ? Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of the Interior Program Tribal Self-Governance Program Assistance Listing: No. 15.022 Award No. GT-OSGT004 Year 2022 Criteria or Specific Requirement In accordance with 2 CFR section 200.303, the Association is required to establish and maintain effective internal control that provides reasonable assurance that the Association is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Timesheets were identified that lacked proper approval by an immediate supervisor to support the timesheet approval policy established by the Association. Cause Oversight in following proper procedure around timesheet approval. Effect or potential effect Individuals may directly charge time to the program for unallowed activity. Questioned Costs None Context We tested 16 samples for employees who charged time to the program. For 9 of those samples, timesheets did not contain proper approval as evidenced on the timesheet. Identification as a repeat finding Not applicable. Recommendation All timesheets should be reviewed and approved by an appropriate supervisor prior to processing payroll processing. Views of Responsible Official and Planned Corrective Action Management agrees with finding. The Association will ensure that the proper internal control procedures over timesheets review and approval process are in place before the timesheets are submitted to payroll for processing.

Finding 2019-002 Reporting ? Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Health and Human Services Program Health Center Program Cluster CFDA: No. 93.224/93.527 Award No. H80CS01127-17-00 Criteria or Specific Requirement Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition Management was not able to produce evidence that Uniform Data System (UDS) report was reviewed and approved prior to submission to the granting agency. Cause Turnover in the program manager position resulted in evidence of review not being kept in the file. Effect or Potential Effect Information submitted to the granting agency in the UDS report might be incomplete or inaccurate. Questioned Costs None Context Management was not able to produce evidence that the UDS report was reviewed and approved prior to submission to the granting agency. Recommendation A policy should be established and enforced for maintaining evidence of controls performed over applicable compliance requirements. Evidence of review and approval of the report should be retained by management and be available for inspection. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Refer to the corrective action plan.