MARY'S CENTER FOR MATERNAL AND CHILD CARE INC.

Information on the federal program – Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Per 2 CFR §200.305, non-federal entities must minimize the time between the transfer of federal funds from the U.S. Treasury and the disbursement of those funds for program purposes. Advance payments must be limited to the minimum amounts needed and timed to be in accordance with the entity’s actual, immediate cash requirements. Condition – During our testing of cash management, we were unable to obtain supporting documentation for one of the draws selected for testing to verify that the time between the transfer and disbursement of funds was minimized. Further, we noted the Organization does not have a formal policy for federal cash drawdowns. Cause – The Organization did not have a formal policy or suf…

Corrective action: Finding Number: 2025-002 Planned Corrective Action: Management has implemented enhanced cash management and grant monitoring procedures, including strengthened review of draw requests, improved documentation requirements, and closer reconciliation of grant expenditures to amounts drawn. In addition, the Organization is undertaking process improvements to streamline grant accounting and reporting activities, improve the timeliness of expense recognition, and enhance overall oversight of federal awards. Management expects these actions will strengthen compliance with federal cash management requirements and reduce the risk of future occurrences. Anticipated Completion Date: 12/31/2026 Res…

Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Health centers must comply with federal reporting requirements. Condition – The Organization did not have data to support certain line items reported on the Uniform Data System (UDS) report filed. Within Table 5 of the UDS report, the amounts reported within line 8 column B, line 8, column B2, line 10A, column B, and line 10A, column B2, were not supportable by underlying data. Within Table 8A of the UDS report, the amounts reported within line 17 column C, line 1, column C, and line 3, column C, were not supportable by underlying data. Within Table 9E of the UDS report, the amounts reported within line 1G column A, and line 1Q, column A, were not supportable by underlying data. Cause – Internal controls we…

Corrective action: Finding Number: 2024-002 Planned Corrective Action: Management acknowledged several amendments were made to the UDS tables that support the calculation that was filed. A lack of document retention resulted in the final amended calculation not being saved in a central, shared site that would support the amount filed. In future periods, management will have processes and procedures in place to require proper retention of reconciliation and tie-out of supporting documentation to final filings which will alleviate this finding. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Tony Ricciardella, Interim Chief Financial Officer and Alison Roca, Controller

Information on the federal program – Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition – During our review of the Organization’s sliding fee calculations, we noted 3 patient accounts with incorrectly calculated sliding fee adjustments. Cause – The Organization did not have internal controls in place to ensure that the correct sliding fee adjustment was applied to patient accounts. Effect or potential effect – Patients received incorrect sliding fee adjustments resulting in an incorrect patient responsibility. Questioned costs – None Context – Out of a population of 43,633 patien…

Corrective action: Finding Number: 2024-003 Planned Corrective Action: Management acknowledged the sliding fee adjustment errors resulted from incorrect calculation of sliding fee discount. Management will add an additional layer of review over the application of the sliding fee scale. Further, the Organization will implement a process to periodically review sliding fee adjustments throughout the year for accuracy. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Tony Ricciardella, Interim Chief Financial Officer and Alison Roca, Controller

Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services; Federal Award No. H8FCS41441 for project period April 1, 2021 through December 31, 2023. Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” is…

Corrective action: Management has assessed that all supporting documentation that was unable to be provided for audit support was related to transactions that occurred on the legacy accounting system. The legacy accounting system did not allow for centralized/shared data storage, and as a result, it caused personnel to store information in different locations. In May 2023, the organization made the transition to the new accounting system where data can easily be centralized/shared. Management has also implemented policies and procedures that require review of documents within the accounting system prior to approval, thus creating internal controls to prevent a lack of supporting documentation for future report…

Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Health centers must comply with federal reporting requirements. Condition – The Organization did not accurately complete its Federal Financial Report, and the Organization did not have data to support certain line items reported on the Uniform Data System (UDS) report filed. The Federal Financial Report was submitted with incorrect data for lines 10j and 10n. Within Table 8A of the UDS report, the amounts reported within line 17 column C, line 1, column C, and line 3, column C, were not supportable by underlying data. Cause – There was a lack of detailed review of the Federal Financial Report by someone with knowledge of the reporting requirements, and internal controls were not in place to ensure proper…

Corrective action: Management acknowledged several amendments were made to the UDS tables that support the final calculation that was filed. A lack of document retention resulted in the final amended calculation not being saved in a central shared site that would support the amount filed. In future periods, management has processes and procedures in place to require reconciliation and tie-out of supporting documentation to final filings which will alleviate this finding. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Tony Ricciardella, Interim Chief Financial Officer and Alison Roca, Controller

Information on the federal program _ Assistance Listing Number 10.557, Special Supplemental Nutrition Program for Women, Infants, and Children, Department of Agriculture; Assistance Listing Number 93.676, Unaccompanied Alien Children Program, Department of Health and Human Services; Assistance Listing Number 93.870, Maternal, Infant and Early Childhood Home Visiting Grant Program, Department of Health and Human Services Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control…

Corrective action: Management acknowledges that the organization operated with provisional rates in 2023 and did not update to actual indirect rates. Management has calculated actual rates for 2023, will update its NICRA for new provisional rates for 2025 and will institute a policy of updated rates on an annual basis including computing actual indirect cost rates at the conclusion of each audit. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Tony Ricciardella, Interim Chief Financial Officer and Alison Roca, Controller

Information on the federal program _ Assistance Listing Number 93.224/93.527; Health Center Program Cluster; Department of Health and Human Services Criteria or specific requirement – Activities Allowed/Unallowed and Cost Principles; As stated in 2 CFR §200.303, the non-federal entity (i.e., the Organization) must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Con…

Corrective action: Management has assessed that all supporting documentation that was unable to be provided for audit support was related to transactions that occurred on the legacy accounting system. The legacy accounting system did not allow for centralized/shared data storage, and as a result, caused personnel to store information in different locations. In May 2023, the organization made the transition to the new accounting system where data can easily be centralized/shared. Management has also implemented policies and procedures that require review of documents within the accounting system prior to approval, thus creating internal controls to prevent a lack of supporting documentation for future reporting…

Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders…

Corrective action: A detailed Procurement process currently exists; however, due to staff turnover we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. (1) Mary's Center will establish and maintain procurement records and files. The physical records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. (2) Mary's Center will document in the procurement files some form of cost or price analysis made in connec…

Information on the federal program – All federal programs Criteria or specific requirement – According to 2 CFR §200.303, the non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, according to 2 CFR §200.318 Procurement standards, the non-federal entity must maintain records sufficient to detail the history of procurement. These re…

Corrective action: A detailed Procurement process currently exists; however, due to staff turnover we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. (1) Mary's Center will establish and maintain procurement records and files. The physical records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. (2) Mary's Center will document in the procurement files some form of cost or price analysis made in connec…

Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. …

Corrective action: Views of Responsible Officials: Mary's Center Finance team has revised our Financial Policies and Procedures Manual to further outline our standard operating procedures (SOPs) and created additional supporting documentation that details SOPs for current processes/procedures. We have also defined in this supporting documentation contingency plans to combat the lack of knowledge transfer that can occur with unexpected staff attrition. Lastly, our Director of Grants has begun reconciling our SEFA report monthly to ensure we are accurate in our reporting and can proactively address any issues.

Federal Programs: 93.110 Criteria: Grantor requires that the Center submit programmatic reports in accordance with the schedules indicated in its grant agreements. Internal controls should provide for these reports to report the measurement of the recipient's performance to show achievement of program goals and objectives, share lessons learned, improve program outcomes, and foster adoption of promising practices (2 CFR §200.301(a)). Condition: During our audit, we were notified by management that certain programmatic reports were not submitted within the deadlines outlined in the grant agreements. We also noted the Center did not have evidence that certain programmatic reports were submitted in accordance with specific grant terms. Cause: The Center did not have the proper internal controls in place to ensure proper management of the Federal award(s) in compliance with the terms and con…

Corrective action: Views of Responsible Officials: Mary's Center is currently formalizing the existing checklist of all Programmatic Reports required for each of our Federal Grants. This checklist is being reviewed and updated by our Director of Grants. In addition, there is now a bi-weekly meeting in place between the Programmatic and Finance teams to address any changes or updates to grants. Lastly, a Grants liaison was recently employed at Mary's Center. This person will act as the conduit between our Programmatic and Finance teams and help maintain this checklist on a going forward basis.

Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted one instance where a cash disbursement was not supported with corroborating documentation (i.e. invoices, valuation documentation, contracts, etc.). While we understand that this was a year of higher…

Corrective action: Views of Responsible Officials: Mary's Center now has the following process in place to directly address this issue. Please see details below: All cash disbursements must be supported by an automated invoice, contract, and/or valuation documentation in the financial accounting system (Sage Intacct) prior to payment. The same process applies for both purchase order and nonpurchase order related invoices. Any individual invoice exceeding $10,000 requires approval from both Department and Finance leadership prior to payment. Monthly Finance Team meetings are held to address staff's outstanding questions/concerns about workflows and processes.

Criteria: According to 2 CFR §200.303, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, according to 2 CFR §200.318 Procurement standards, the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale fo…

Corrective action: Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. 2. Mary's Center will document in the procurement fil…

Federal Programs: 93.224, 93.870 Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.414 Subpart F, Appendix IV, Section C.2.f, the provisional and final rates must be negotiated where neither predetermined nor fixed rates are appropriate. Predetermined or fixed ra…

Corrective action: Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being requested, the Program Manager alerts the Senior Grant Accountant assigned to the grant and provides supporting documentation from the Grant funder of an addendum to the existing Grant agreement. If for any reason the Finance team is using an upward or downward adjustment to the provisional indirect rate or what was agreed upon in the Grant agreement the EVP Finance and Director of Grants must approve t…

Federal Programs: All Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.512(a)(1) the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitte…

Corrective action: Views of Responsible Officials: As detailed in our Policy and Procedure document Mary's Center has developed a detailed pre-audit process to ensure our formal-year end closing occurs with no issues. In preparation for our annual audit, all accounts will be reconciled prior to the beginning of the audit period using a detailed workflow. The workflow includes a formalized checklist and workplan with the following tasks that need to be completed:  Patient Receivable Schedule Reconciliation  Patient Revenue Reconciliation  Asset and Liability Accounts Reconciliation Views of Responsible Officials (continued): Pre-Audit reconciliation efforts and adherence to the workflow will be co-led by the…

Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, …

Corrective action: Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. This policy includes a required annual screening of any current vendors and has now been extended to contractors and consultants also. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/…

Finding 2021-003: Supporting Documentation Criteria: As stated in 2 CFR 200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or in the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted several instances where cash disbursements were not supported with corroborating documentation (i.e. invoices, valuation documentation, contracts, etc.). W…

Corrective action: Views of Responsible Officials: The organization?s move to a new financial software solution will provide the digitalization of invoices and documentation related to vendors and importance to the procurement process. Additionally, finance team leadership will move from annual to quarterly trainings for leadership to reiterate the procurement policy and process.

Finding 2021-004: Indirect Cost Rate Calculation Federal Programs: 93.224, 93.926, 10.557 Criteria: According to 2 CFR 200.414 Subpart F, Appendix IV, Section C.2.f, the provisional and final rates must be negotiated where neither predetermined nor fixed rates are appropriate. Predetermined or fixed rates may replace provisional rates at any time prior to the close of the organization's fiscal year. If that event does not occur, a final rate will be established and upward or downward adjustments will be made based on the actual allowable costs incurred for the period involved. Condition: During our review of the Center's indirect cost rate calculation, we noted the indirect costs were not properly calculated and reconciled with the program income statements according to each grants' approved indirect cost rate. Cause: The Center did not perform a true-up of indirect rate costs based …

Corrective action: Views of Responsible Officials: The organization received the new approved rate in the middle of the grant year for most of the grants and while some of the funders were willing to accept and pay up a retroactive adjustment, others were not. Going forward, we will create new account lines to record non-billable differences between the final approved rate and each grant budget approved fringe and indirect rates for audit purposes.

Finding 2021-005: Reporting Federal Programs: 93.224 and 93.926 Criteria: Grantor requires that the Center submit a quarterly Federal Financial Report (FFR), SF- 425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: During our audit, we noted two (2) instances where a Federal financial report was not submitted within the deadlines outlined in the grant agreement. Cause: The Center did not have the proper internal controls in place around its grants management to ensure timely filing of its Federal financial reports as part of compliance with the Federal regulations. Effect or Potential Effect: Without proper management of the Center's Federal financial reporting requirements, the Center risks missing filing reports in their entirety, thus risking its Federal funding. Questioned Costs: …

Corrective action: Views of Responsible Officials: Finance, Development and Programs teams have begun implementing improvements which will help to meet this goal. Staff turnover in high level grants positions, in addition to the large volume of grant awards on hand resulted in some of the grants reporting not being completed in a timely fashion. The organization has created a new role (Director of Grants Accounting) which will oversee the full life cycle grants process and will ensure reports are submitted on time.