Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster
Assistance Listing Number: 93.224 and 93.527
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021
– March 31, 2023, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
A grantee's system of internal control should include processes to review after-the-fact interim charges made to a Federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice.
Condition:
The Organization did not verify that the wages being charged to the grant were consistent with the amount paid to employees. The internal controls over compliance were not properly set up to identify this until the audit testing was complete. In addition, the organization had inconsistent methods of
tracking wages being charged to federal grants. Records were not kept consistently to support how employee wages were identified prior to drawdowns being submitted.
Questioned Costs:
As a result of our audit procedures, we identified questioned costs in the amount of $977 related to the Organization charging wages in excess of the amount actually paid to the employee.
Context:
One (1) of forty (40) transactions
Cause:
The organization had inconsistent methods of tracking salaries and wages charged to the grant and did not verify that the wages charged to the grant matched what was incurred by the Organization and paid to the employee.
Effect:
The Organization may inadvertently over charge the grant for wages that were not incurred or paid to employees. Repeat Finding:
No.
Recommendation:
We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a consistent process for identifying the specific employees and wages being charged to each grant.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster
Assistance Listing Number: 93.224 and 93.527
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021
– March 31, 2023, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
A grantee's system of internal control should include processes to review after-the-fact interim charges made to a Federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice.
Condition:
The Organization did not verify that the wages being charged to the grant were consistent with the amount paid to employees. The internal controls over compliance were not properly set up to identify this until the audit testing was complete. In addition, the organization had inconsistent methods of
tracking wages being charged to federal grants. Records were not kept consistently to support how employee wages were identified prior to drawdowns being submitted.
Questioned Costs:
As a result of our audit procedures, we identified questioned costs in the amount of $977 related to the Organization charging wages in excess of the amount actually paid to the employee.
Context:
One (1) of forty (40) transactions
Cause:
The organization had inconsistent methods of tracking salaries and wages charged to the grant and did not verify that the wages charged to the grant matched what was incurred by the Organization and paid to the employee.
Effect:
The Organization may inadvertently over charge the grant for wages that were not incurred or paid to employees. Repeat Finding:
No.
Recommendation:
We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a consistent process for identifying the specific employees and wages being charged to each grant.
Finding 2023-003 – Procurement
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support
Assistance Listing Number: 93.224, 93.527 and 93.526
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02;
C8EC44826-01-00
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021– March 31, 2023; September 15, 2021 – September 15, 2024, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
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 for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318). Additionally, the non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR 200.320 which includes five acceptable methods of procurement which vary based on the size of the purchase and nature of the expense.
Condition:
For a portion of the year under audit, the Organization did not have a procurement policy that complied with 2 CFR 200.320 and did not maintain sufficient documentation to support the use of an approved or prequalified vendor listing. As a result of this, the Organization incorrectly applied the micro-purchase methodology to transactions which qualified for the simplified acquisition method. Questioned Costs:
Unknown.
Context:
Five (5) of five (5) transactions selected for procurement testing.
Cause:
The Organization did not have a procurement policy which was consistent with 2 CFR 200.230 during a specific period of time during the year under audit. During the last quarter of the fiscal year, the Organization did update its procurement policy to be consistent with the requirements of the Uniform
Guidance.
Effect:
Without an appropriate procurement policy, there is a potential to use federal grants in a manner which is not the most efficient and economical.
Repeat Finding:
No.
Finding 2023-003 – Procurement
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support
Assistance Listing Number: 93.224, 93.527 and 93.526
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02;
C8EC44826-01-00
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021– March 31, 2023; September 15, 2021 – September 15, 2024, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
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 for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318). Additionally, the non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR 200.320 which includes five acceptable methods of procurement which vary based on the size of the purchase and nature of the expense.
Condition:
For a portion of the year under audit, the Organization did not have a procurement policy that complied with 2 CFR 200.320 and did not maintain sufficient documentation to support the use of an approved or prequalified vendor listing. As a result of this, the Organization incorrectly applied the micro-purchase methodology to transactions which qualified for the simplified acquisition method. Questioned Costs:
Unknown.
Context:
Five (5) of five (5) transactions selected for procurement testing.
Cause:
The Organization did not have a procurement policy which was consistent with 2 CFR 200.230 during a specific period of time during the year under audit. During the last quarter of the fiscal year, the Organization did update its procurement policy to be consistent with the requirements of the Uniform
Guidance.
Effect:
Without an appropriate procurement policy, there is a potential to use federal grants in a manner which is not the most efficient and economical.
Repeat Finding:
No.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster
Assistance Listing Number: 93.224 and 93.527
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021
– March 31, 2023, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
A grantee's system of internal control should include processes to review after-the-fact interim charges made to a Federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice.
Condition:
The Organization did not verify that the wages being charged to the grant were consistent with the amount paid to employees. The internal controls over compliance were not properly set up to identify this until the audit testing was complete. In addition, the organization had inconsistent methods of
tracking wages being charged to federal grants. Records were not kept consistently to support how employee wages were identified prior to drawdowns being submitted.
Questioned Costs:
As a result of our audit procedures, we identified questioned costs in the amount of $977 related to the Organization charging wages in excess of the amount actually paid to the employee.
Context:
One (1) of forty (40) transactions
Cause:
The organization had inconsistent methods of tracking salaries and wages charged to the grant and did not verify that the wages charged to the grant matched what was incurred by the Organization and paid to the employee.
Effect:
The Organization may inadvertently over charge the grant for wages that were not incurred or paid to employees. Repeat Finding:
No.
Recommendation:
We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a consistent process for identifying the specific employees and wages being charged to each grant.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster
Assistance Listing Number: 93.224 and 93.527
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021
– March 31, 2023, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
A grantee's system of internal control should include processes to review after-the-fact interim charges made to a Federal award based on budget estimates. 45 CFR 75.430(i)(1). In addition, CFR 200.430 indicates costs of compensation are allowable to the extent that they satisfy the specific requirement of determining and supporting the salary and wages based on records that accurately reflect the work performed. Salaries and wages charged to a grant should be tagged/identified by employee to ensure expenses are not counted or charged twice.
Condition:
The Organization did not verify that the wages being charged to the grant were consistent with the amount paid to employees. The internal controls over compliance were not properly set up to identify this until the audit testing was complete. In addition, the organization had inconsistent methods of
tracking wages being charged to federal grants. Records were not kept consistently to support how employee wages were identified prior to drawdowns being submitted.
Questioned Costs:
As a result of our audit procedures, we identified questioned costs in the amount of $977 related to the Organization charging wages in excess of the amount actually paid to the employee.
Context:
One (1) of forty (40) transactions
Cause:
The organization had inconsistent methods of tracking salaries and wages charged to the grant and did not verify that the wages charged to the grant matched what was incurred by the Organization and paid to the employee.
Effect:
The Organization may inadvertently over charge the grant for wages that were not incurred or paid to employees. Repeat Finding:
No.
Recommendation:
We recommend the Organization implement a comprehensive and thorough process to review all wages charged to federal and state grant prior to initiating a drawdown request or submitting a reimbursement request to the grantor. As part of this, the Organization should implement a consistent process for identifying the specific employees and wages being charged to each grant.
Finding 2023-003 – Procurement
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support
Assistance Listing Number: 93.224, 93.527 and 93.526
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02;
C8EC44826-01-00
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021– March 31, 2023; September 15, 2021 – September 15, 2024, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
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 for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318). Additionally, the non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR 200.320 which includes five acceptable methods of procurement which vary based on the size of the purchase and nature of the expense.
Condition:
For a portion of the year under audit, the Organization did not have a procurement policy that complied with 2 CFR 200.320 and did not maintain sufficient documentation to support the use of an approved or prequalified vendor listing. As a result of this, the Organization incorrectly applied the micro-purchase methodology to transactions which qualified for the simplified acquisition method. Questioned Costs:
Unknown.
Context:
Five (5) of five (5) transactions selected for procurement testing.
Cause:
The Organization did not have a procurement policy which was consistent with 2 CFR 200.230 during a specific period of time during the year under audit. During the last quarter of the fiscal year, the Organization did update its procurement policy to be consistent with the requirements of the Uniform
Guidance.
Effect:
Without an appropriate procurement policy, there is a potential to use federal grants in a manner which is not the most efficient and economical.
Repeat Finding:
No.
Finding 2023-003 – Procurement
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support
Assistance Listing Number: 93.224, 93.527 and 93.526
Federal Award Identification
Number: H80CS00824-21-00; H80CS00824-22-00; H8FCS41534-01-02;
C8EC44826-01-00
Award Periods: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024; April 1, 2021– March 31, 2023; September 15, 2021 – September 15, 2024, respectively
Type of Finding: Compliance and material weakness in internal control over compliance
Criteria:
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 for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318). Additionally, the non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR 200.320 which includes five acceptable methods of procurement which vary based on the size of the purchase and nature of the expense.
Condition:
For a portion of the year under audit, the Organization did not have a procurement policy that complied with 2 CFR 200.320 and did not maintain sufficient documentation to support the use of an approved or prequalified vendor listing. As a result of this, the Organization incorrectly applied the micro-purchase methodology to transactions which qualified for the simplified acquisition method. Questioned Costs:
Unknown.
Context:
Five (5) of five (5) transactions selected for procurement testing.
Cause:
The Organization did not have a procurement policy which was consistent with 2 CFR 200.230 during a specific period of time during the year under audit. During the last quarter of the fiscal year, the Organization did update its procurement policy to be consistent with the requirements of the Uniform
Guidance.
Effect:
Without an appropriate procurement policy, there is a potential to use federal grants in a manner which is not the most efficient and economical.
Repeat Finding:
No.