2022-001 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Activities Allowed and Allowable Costs, Period of Performance, Cash Management and Reporting Material Weakness in Internal Control over Compliance Criteria: 2CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Effect: Without established controls over activities allowed and allowable costs, period of performance, cash management and reporting, there is a reasonable possibility that the Coalition would not detect noncompliance in the normal course of performing duties and correct them in a timely manner. Questioned Costs: None reported. Context: Testing was performed over the compliance requirements as follows: -Activities Allowed, Allowable Costs and Period of Performance ? A non-statistical sample of 60 nonpayroll transactions were selected for testing, accounting for approximately $379,111 of $749,012 total non-payroll costs charged to the federal award. Additionally, all Executive Director wages charged to the federal award were tested. -Cash Management ? A non-statistical sample of 13 out of 64 draw requests were selected for testing. -Reporting ? the close-out report required to be filed in the fiscal year was tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval. Views of Responsible Officials: Management agrees with the finding.
2022-002 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Equipment and Real Property Management Material Weakness in Internal Control over Compliance Criteria: 2CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. 2 CFR 200.313(d)(2) requires a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. b) Property records lack descriptive elements as required by 2 CFR 200.313(d)(1), including source of funding, acquisition date and cost. c) A physical inventory of equipment has not been performed within the last two years. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Additionally, the Coalition was unaware of federal requirements pertaining to the descriptive elements of property records required and the completion of a physical inventory of property every two years. Effect: Without established controls over equipment and real property management, there is risk that equipment could be misappropriated, unallowable equipment purchases could be charged to the federal award and an increased risk federal agency wouldn?t be reimbursed if federal-funded equipment was disposed of. Questioned Costs: None reported. Context: There were three fixed asset purchases charged to the federal award within the fiscal year of which all were tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over equipment compliance requirements, comply with property record requirements, and perform a bi-annual physical inventory of the equipment. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.318 requires documentation to be retained to detail the history of procurements. In addition, as outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. b) 15 instances identified in our sample of expenditures in which the transaction exceeded the Coalition?s micro-purchase threshold, required a price analysis, however, the price analysis was not documented or completed. c) The Coalition?s procurement policy does not include all the required elements as outlined in the Uniform Guidance. d) Five vendors were not verified against the central contractor registry prior to the expenses being incurred to ensure that the vendor was not suspended or debarred. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Additionally, the Coalition did not retain documentation to support the history of procurement in accordance with Uniform Guidance. Lastly, the internal control process ensuring vendors are verified against the central contractor registry was not followed. Effect: Without established controls over procurement, suspension and debarment, there is a reasonable possibility that the Coalition would not detect errors in the normal course of performing duties and correct them in a timely manner. Without retaining supporting documentation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Lastly, failing to verify vendors against the central contractor registry may result in the Coalition contracting for services with ineligible parties. Questioned Costs: None reported. Context: Testing was performed over the compliance requirements as follows; -Procurement - A non-statistical sample of 60 non-payroll transactions were selected for testing, accounting for approximately $379,111 of $749,012 total non-payroll costs charged to the federal award. -Suspension and Debarment - all five vendors with transactions equaling or exceeding $25,000 were selected for suspension and debarment testing. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over procurement, suspension and debarment, update the procurement policy to include Uniform Guidance elements, retain documentation on price analysis for transactions over the micro-purchase threshold and verification of vendors against the central contractor registry. Views of Responsible Officials: Management agrees with the finding.
2022-004 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Earmarking Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. b) No ongoing analysis is completed over comparison of actual expenditures to earmarked expenditures. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures to track actual costs to earmarked expenditure thresholds. Effect: Without established controls over earmarking, there is a reasonable possibility that the Coalition would not detect errors in the normal course of performing duties and correct them in a timely manner. Lack of an ongoing analysis of budgeted expenses to actual could result in the Coalition expending more funds than originally earmarked within the grant agreement. Questioned Costs: None reported. Context: Testing was performed over each of the three earmarking requirements identified within the grant agreement. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over earmarking, including a periodic analysis of actual expenditures to earmarked expenditures. Views of Responsible Officials: Management agrees with the finding.
2022-001 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Activities Allowed and Allowable Costs, Period of Performance, Cash Management and Reporting Material Weakness in Internal Control over Compliance Criteria: 2CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Effect: Without established controls over activities allowed and allowable costs, period of performance, cash management and reporting, there is a reasonable possibility that the Coalition would not detect noncompliance in the normal course of performing duties and correct them in a timely manner. Questioned Costs: None reported. Context: Testing was performed over the compliance requirements as follows: -Activities Allowed, Allowable Costs and Period of Performance ? A non-statistical sample of 60 nonpayroll transactions were selected for testing, accounting for approximately $379,111 of $749,012 total non-payroll costs charged to the federal award. Additionally, all Executive Director wages charged to the federal award were tested. -Cash Management ? A non-statistical sample of 13 out of 64 draw requests were selected for testing. -Reporting ? the close-out report required to be filed in the fiscal year was tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval. Views of Responsible Officials: Management agrees with the finding.
2022-002 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Equipment and Real Property Management Material Weakness in Internal Control over Compliance Criteria: 2CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. 2 CFR 200.313(d)(2) requires a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. b) Property records lack descriptive elements as required by 2 CFR 200.313(d)(1), including source of funding, acquisition date and cost. c) A physical inventory of equipment has not been performed within the last two years. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Additionally, the Coalition was unaware of federal requirements pertaining to the descriptive elements of property records required and the completion of a physical inventory of property every two years. Effect: Without established controls over equipment and real property management, there is risk that equipment could be misappropriated, unallowable equipment purchases could be charged to the federal award and an increased risk federal agency wouldn?t be reimbursed if federal-funded equipment was disposed of. Questioned Costs: None reported. Context: There were three fixed asset purchases charged to the federal award within the fiscal year of which all were tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over equipment compliance requirements, comply with property record requirements, and perform a bi-annual physical inventory of the equipment. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.318 requires documentation to be retained to detail the history of procurements. In addition, as outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. b) 15 instances identified in our sample of expenditures in which the transaction exceeded the Coalition?s micro-purchase threshold, required a price analysis, however, the price analysis was not documented or completed. c) The Coalition?s procurement policy does not include all the required elements as outlined in the Uniform Guidance. d) Five vendors were not verified against the central contractor registry prior to the expenses being incurred to ensure that the vendor was not suspended or debarred. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Additionally, the Coalition did not retain documentation to support the history of procurement in accordance with Uniform Guidance. Lastly, the internal control process ensuring vendors are verified against the central contractor registry was not followed. Effect: Without established controls over procurement, suspension and debarment, there is a reasonable possibility that the Coalition would not detect errors in the normal course of performing duties and correct them in a timely manner. Without retaining supporting documentation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Lastly, failing to verify vendors against the central contractor registry may result in the Coalition contracting for services with ineligible parties. Questioned Costs: None reported. Context: Testing was performed over the compliance requirements as follows; -Procurement - A non-statistical sample of 60 non-payroll transactions were selected for testing, accounting for approximately $379,111 of $749,012 total non-payroll costs charged to the federal award. -Suspension and Debarment - all five vendors with transactions equaling or exceeding $25,000 were selected for suspension and debarment testing. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over procurement, suspension and debarment, update the procurement policy to include Uniform Guidance elements, retain documentation on price analysis for transactions over the micro-purchase threshold and verification of vendors against the central contractor registry. Views of Responsible Officials: Management agrees with the finding.
2022-004 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Earmarking Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The following matters were identified during testing: a) No independent secondary level of review or approval is performed. One employee is involved in preparing, reviewing and approving information. b) No ongoing analysis is completed over comparison of actual expenditures to earmarked expenditures. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures to track actual costs to earmarked expenditure thresholds. Effect: Without established controls over earmarking, there is a reasonable possibility that the Coalition would not detect errors in the normal course of performing duties and correct them in a timely manner. Lack of an ongoing analysis of budgeted expenses to actual could result in the Coalition expending more funds than originally earmarked within the grant agreement. Questioned Costs: None reported. Context: Testing was performed over each of the three earmarking requirements identified within the grant agreement. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval over earmarking, including a periodic analysis of actual expenditures to earmarked expenditures. Views of Responsible Officials: Management agrees with the finding.