Criteria: 45 CFR section 75.303 (a) states non-federal entities 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 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). 45 CFR section 75.303 (b) states non-federal entities must: Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. Recipients of provider relief funds must support all expenses with adequate documentation and maintain proper control documentation to substantiate that these funds were used for health care-related expenses or lost revenues attributable to coronavirus. Condition Found, Including Perspective: There is no documentation to evidence of management’s review of the HRSA portal submission prior to their submission to the U.S. Department of Health and Human Services. Possible Cause and Effect: While the System maintains that review did take place prior to the portal submission, controls were not designed or implemented effectively to maintain evidence of management’s review. Questioned Costs: None.
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 45 CFR section 75.303 (a) states non-federal entities 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 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). 45 CFR section 75.303 (b) states non-federal entities must: Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. Recipients of provider relief funds must support all expenses with adequate documentation and maintain proper control documentation to substantiate that these funds were used for health care-related expenses or lost revenues attributable to coronavirus. Condition Found, Including Perspective: There is no documentation to evidence of management’s review of the HRSA portal submission prior to their submission to the U.S. Department of Health and Human Services. Possible Cause and Effect: While the System maintains that review did take place prior to the portal submission, controls were not designed or implemented effectively to maintain evidence of management’s review. Questioned Costs: None.
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None
Criteria: 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502. Condition Found, Including Perspective: The Schedule of Expenditures of Federal Awards (SEFA) prepared by management contained differences between federal expenditures reported and the amounts supported by the underlying books and records. In addition, there is no evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA to ensure that amounts are properly presented. Possible Cause and Effect: While the System performs a review during the compilation of the SEFA, controls were not designed or implemented effectively to identify errors in the SEFA and to maintain evidence of management’s detail review of the reconciliation between the underlying expenditure detail to the SEFA. Questioned Costs: None