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Press Release:  September 17, 2013

HRSA OIG Compliance Letter


Over the past few years, the Office of Inspector General (OIG) has issued reports from audits performed at section 330 federally-funded FQHCs in many states and regions.  These audits and resultant findings and recommendations were an assessment of the FQHCs’ capacity to manage, account for and report ARRA/HRSA funds, and to operate HRSA-funded health centers in accordance with federal regulations.  Clearly, the federal government wants to know how FQHCs are spending federal dollars, along with determining the health centers’ capabilities relative to managing, operating, and remaining fiscally viable. The mission of the OIG, as mandated by Public Law 95-452, as amended, is to protect the integrity of DHH programs, including HRSA’s, as well as the health and welfare of beneficiaries served by those programs.


For instance, in a TX case, the OIG’s findings indicated that the FQHC didn’t have adequate controls over its financial management system nor did it have adequate procurement procedures. The OIG recommended that HRSA require the health center refund $12.5MM to the federal government.  In a OH case, the OIG found that although the FQHC managed and accounted for federal funds in accordance with federal regulations, it lacked written policies and procedures for accounting for property, cash receipts and disbursements, purchasing, FDIC limit and federal grant reporting.  In a CT case, the OIG found that the FQHC did not have adequate policies and procedures to ensure that it maintained all federal funds (ARRA/HRSA) and insured accounts and to protect whistle-blowers from punishment and discrimination.  It has been demonstrated that audit activity continues to increase and that health centers face increasing risks of audits, disallowances and possible recoupments of federal dollars.


Executive Resources, LLC (EXEC) is pleased to announce a new product line to help your PCA’s member health centers address these challenging issues.  We have formed strategic alliances with CBIZ and its portfolio of integrated services along with a healthcare law firm well-versed in section 330 proceedings to assist FQHCs in conducting a proactive review of current operations to ensure compliance with a myriad of federal regulations that apply.


Executive’s overall objective would be to assess the overall financial, legal, and operational issues of a health center relative to compliance with GAAP and legal issues (i.e. OIG, Stark, IRS), especially regarding risk and areas of concern to the section 330 grantee and if applicable, the co-applicant.   EXEC and our partners will assess the financial, legal, and operational viability as an ongoing federally-funded community-based organization, the capacity to manage and account for federal funds, and the capability to operate in accordance with federal regulations, including section 330 guidance.  Our review will concentrate on performing tasks, tests, and auditing procedures relative to financial, legal, and operational management systems in order to assess the health center’s ability to administer federally-funded projects.


If you are interested in finding out more about how EXEC can help safeguard your PCA’s member health centers’ assets by performing this review, please call Larry Sargent or Harry Wright at 732-974-7200.  We will conduct this review in accordance with GAAP and HRSA’s Health Center Site Visit Guide, in addition to meeting federal requirements imposed by OIG, Stark, and IRS. We look forward to hearing from you in the near future.  

Contact us, and we'll be happy to tell you exactly how we can address your particular institutional situation.