West Oakland Health Council (Baywell Health)Non-Profit

Criteria: In accordance with Uniform Guidance 200.334, the Organization has retention requirements for records. Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed annually, from the date of submission of the annual financial report, as reported to the federal awarding agency. Condition and Context: During our expenditure and sliding fee testing, we noted that adequate supporting documentation was not maintained for some of the sliding fee calculation and payroll expenditures tested. The Organization lacked adequate controls over its sliding fee discount program to ensure applications were properly processed, recorded, and received the correct discount by not maintaining proper documentation. The finding relates to maintaining records in accordance with Federal regulations. Cause: The Organization experienced employee turnover in several departments. Effect or Potential Effect: If a non-federal entity fails to comply with federal statues, the federal awarding agency may take one or more of the following actions, (a) temporarily withhold cash payments pending correction of the deficiency by the non-federal entity, (b) disallow all or part of the cost of the activity or action not in compliance, (c) wholly or partly suspend or terminate the federal award, (d) initiate suspension proceedings, (e) withhold further federal awards for the program or (f) take other legally available remedies. Repeat Finding: Yes Recommendation: The Organization should take measures to maintain supporting documents in an electronic environment that are backed up electronically to prevent any loss of data in the event of a fire or breach. Client Response: Management acknowledges this condition related to lack of adequate controls over the sliding fee discount program and is creating controls that will assure compliance with requirements.

Condition: The Council lacked adequate controls over its sliding fee discount program to ensure applications were properly processed, recorded, and received the correct discount. For three of the 40 patient files reviewed who received a sliding fee discount, patient information was inadequate to determine the proper sliding fee discount or the patient was given incorrect discounts based on information provided. Criteria: Health centers must prepare and apply a sliding fee discount schedule and policy so that the amounts owed for health center services by eligible patients are adjusted based on the patient’s ability to pay (42 USC 254(k)(3)€, (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Cause: The Council did not always follow the review process in place to verify that eligible patients received the applicable sliding fee discount according to the Council’s policy. Effect: The Council’s SFS patients’ services were not properly discounted; therefore, those patients were not charged the correct discounted fee in accordance with federal requirements. Recommendation: It is recommended to develop proper controls around the collection of sliding fee applications, verifying required patient information is present and complete, and apply the sliding fee discount in accordance with written policies. This will ensure the Council can detect and prevent ineligible patients from receiving the discount and comply with federal compliance requirements. In order to ensure that SFS discounts are properly calculated and documented, the Council should increase the frequency of random reviews of its SFS applications in order to help detect and correct errors or incomplete applications on a timely basis. View of responsible officials: Management acknowledges this condition related to lack of adequate controls over the sliding fee discount program and is creating controls that will assure compliance with requirements.

Condition: The Council did not meet its financial reporting obligations under the grant during the year. The Council did not file the Data Collection Form (SF-SAC) by the due date of March 31, 2024. Criteria: The Council is required to file the Data Collection Form (SF-SAC) within 30 days of the receipt of the audit or 9 months after year-end, whichever is first. Cause: The Data Collection Form was not filed within the required period due to a delay in preparations for the audit. Effect: The Council was not in compliance with federal regulations. Recommendation: We recommend audit preparations are completed on a timely basis to ensure that the reporting deadline is met. View of responsible officials: Management acknowledges the delay in preparation of the audit due to staffing challenges and has since hired additional resources.

2022-001 Sliding Fee Discount Determination ALN: 93.224 Program: Health Center Program Cluster Agency: US Department of Health and Human Services Compliance Requirement: N- Special Tests and Provisions Repeat Finding: No Criteria: Federal grant compliance provisions require that West Oakland Health Council correctly identify a patient's ability to pay and that the rates for services be adjusted accordingly based on the sliding fee schedule. West Oakland Health Council is required to follow its sliding fee policy when providing discounts to eligible patients. Finding/ Condition: In our sample of 40 tested items, patient information was inadequate to determine the proper sliding fee discount or the patient was given incorrect discounts based on information provided. Questioned Cost: None. Effect: Lack of strict enforcement of the policy of sliding fee eligibility determination and compliance may have resulted in West Oakland Health Council providing discounted services greater to or less than the appropriate amounts to beneficiaries. Cause: Inadequate understanding of the sliding fee program requirements and West Oakland Health Council policies by employees involved in sliding fee determination. Recommendation: Training should be provided to employees on the sliding fee program requirements. West Oakland Health Council should perform regular audits of sliding fee transactions to identify weaknesses in compliance. Views of Responsible Officials and Corrective Action Plan: West Oakland Health Council agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 35.

2022-002 Compliance Over Reporting ALN: 93.224 Program: Health Center Program Cluster Agency: US Department of Health and Human Services Compliance Requirement: (L) Reporting Repeat Finding: No Criteria: Pursuant to the reporting requirement set forth by the Department of Health and Human Services, West Oakland Health Council is required to submit the single audit to the federal audit clearinghouse within the sooner of 30 days of the issuance of the audit report or nine months after the end of West Oakland Health Council?s fiscal year-end. Finding/ Condition: During our reporting period, we noted that the audit was not completed and filed timely. Questioned Cost: None. Effect: The delay in submitting the required report may lead to the granting agency to impose temporary restrictions on the drawdown process. Cause: Staff shortages and delays due to COVID-19 protocol caused delay in the preparation and reporting of the required forms. Recommendation: We recommend the West Oakland Health Council file the year-end audit in a timely manner. Views of Responsible Officials and Corrective Action Plan: West Oakland Health Council agrees with the finding and will implement additional controls to ensure that this does not recur. Please refer to the corrective action plan on page 35.

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