Audit 300238

Federal Agency: Department of Health and Human Services Federal Program Name: COVID 19 - Demonstration Programs to Improve Community Mental Health Services Federal Award Identification Number and Year: H79SM083348 - 2023 Assistance Listing Number: 93.829 Award Period: February 15, 2021 – February 14, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matter - Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the reporting requirements. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organizations internal controls were not sufficient to ensure reports were submitted timely and documentation was maintained to support the details of the reports submitted. Questioned Costs: None. Context: There were 5 of 5 reports selected for testing where the evidence of review was not found before submission. Cause: Insufficient internal controls of reporting. Effect: Inability to determine accuracy and timeliness of reports. Repeat Finding: 2022-001 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Views of Responsible Officials of the Auditee: We are in the process of re-evaluating the reporting process to ensure documentation is maintained to support the reporting requirements.

Federal Agency: Department of Health and Human Services Federal Program Name: COVID 19 - Demonstration Programs to Improve Community Mental Health Services Federal Award Identification Number and Year: H79SM083348 - 2023 Assistance Listing Number: 93.829 Award Period: February 15, 2021 – February 14, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matter - Compliance Criteria: 2 CFR 200.214 outlines the guidelines for suspension and debarment. According to this regulation, non-Federal entities (which includes organizations receiving federal assistance) are subject to the non-procurement debarment and suspension regulations. These regulations implement Executive Orders 12549 and 12689. Specifically, they are covered by 2 CFR part 180. Condition: During our testing, we noted the Organization's internal controls were not sufficient to ensure suspension and debarment verification procedures were performed. Questioned Costs: None. Context: We noted that Cornerstone Montgomery did not verify timely whether 1 of 1 of its vendors to a covered transaction was suspended or debarred prior to entering into the transaction. We were able to verify that the vendor was not suspended or debarred through checking the exclusion database on Sam.gov. Cause: Insufficient internal controls of suspension and debarment. Effect: Lack of determination of if a vendor was suspended or debarred. Repeat Finding: N/A Recommendation: We recommend internal controls over suspension and debarment be implemented. This could include following checklist which includes procedures for verification of whether a vendor is suspended or debarred and having that checklist be required to be reviewed by the program manager prior to entry into a covered transaction. Views of Responsible Officials of the Auditee: A process of more comprehensive review of program requirements will be put in place.

Federal Agency: Department of Health and Human Services Federal Program Name: COVID 19 - Demonstration Programs to Improve Community Mental Health Services Federal Award Identification Number and Year: H79SM083348 - 2023 Assistance Listing Number: 93.829 Award Period: February 15, 2021 – February 14, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matter - Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the reporting requirements. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organizations internal controls were not sufficient to ensure reports were submitted timely and documentation was maintained to support the details of the reports submitted. Questioned Costs: None. Context: There were 5 of 5 reports selected for testing where the evidence of review was not found before submission. Cause: Insufficient internal controls of reporting. Effect: Inability to determine accuracy and timeliness of reports. Repeat Finding: 2022-001 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Views of Responsible Officials of the Auditee: We are in the process of re-evaluating the reporting process to ensure documentation is maintained to support the reporting requirements.

Federal Agency: Department of Health and Human Services Federal Program Name: COVID 19 - Demonstration Programs to Improve Community Mental Health Services Federal Award Identification Number and Year: H79SM083348 - 2023 Assistance Listing Number: 93.829 Award Period: February 15, 2021 – February 14, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matter - Compliance Criteria: 2 CFR 200.214 outlines the guidelines for suspension and debarment. According to this regulation, non-Federal entities (which includes organizations receiving federal assistance) are subject to the non-procurement debarment and suspension regulations. These regulations implement Executive Orders 12549 and 12689. Specifically, they are covered by 2 CFR part 180. Condition: During our testing, we noted the Organization's internal controls were not sufficient to ensure suspension and debarment verification procedures were performed. Questioned Costs: None. Context: We noted that Cornerstone Montgomery did not verify timely whether 1 of 1 of its vendors to a covered transaction was suspended or debarred prior to entering into the transaction. We were able to verify that the vendor was not suspended or debarred through checking the exclusion database on Sam.gov. Cause: Insufficient internal controls of suspension and debarment. Effect: Lack of determination of if a vendor was suspended or debarred. Repeat Finding: N/A Recommendation: We recommend internal controls over suspension and debarment be implemented. This could include following checklist which includes procedures for verification of whether a vendor is suspended or debarred and having that checklist be required to be reviewed by the program manager prior to entry into a covered transaction. Views of Responsible Officials of the Auditee: A process of more comprehensive review of program requirements will be put in place.