FAC Explorer

Audit 306383

FY End
2022-12-31
Total Expended
$1.30M
Findings
24
Programs
3
Organization: Cornerstone Whole Healthcare Organization, Inc. (ID)
Year: 2022 Accepted: 2024-05-15
Auditor: Kdp Certified Public Accountants LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
396975 2022-001 Material Weakness - I
396976 2022-001 Material Weakness - I
396977 2022-001 Material Weakness - I
396978 2022-001 Material Weakness - I
396979 2022-002 Material Weakness - N
396980 2022-002 Material Weakness - N
396981 2022-002 Material Weakness - N
396982 2022-002 Material Weakness - N
396983 2022-003 Material Weakness - C
396984 2022-003 Material Weakness - C
396985 2022-003 Material Weakness - C
396986 2022-003 Material Weakness - C
973417 2022-001 Material Weakness - I
973418 2022-001 Material Weakness - I
973419 2022-001 Material Weakness - I
973420 2022-001 Material Weakness - I
973421 2022-002 Material Weakness - N
973422 2022-002 Material Weakness - N
973423 2022-002 Material Weakness - N
973424 2022-002 Material Weakness - N
973425 2022-003 Material Weakness - C
973426 2022-003 Material Weakness - C
973427 2022-003 Material Weakness - C
973428 2022-003 Material Weakness - C

Programs

ALN Program Spent Major Findings
93.211 Telehealth Programs $475,989 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $15,660 Yes 3
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $8,685 - 0

Contacts

Name Title Type
FHEJFWMPDX59 Jennifer Yturriondobeitia Auditee
2088999012 Aria Bettinger Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Organization has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of Cornerstone Whole Healthcare Organization, Inc. (the Organization) under programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, change in net assets, functional expenses, or cash flows of the Organization.
Title: SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Organization has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The Organization did not have any awards that were passed through to subrecipients for the year ended December 31, 2022.

Finding Details

Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-001
2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-002
2022-002 – Special Tests Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this Act shall clearly state: (1) the percentage of the total costs of the program or project which will be financed with Federal money; (2) the dollar amount of Federal funds for the project or program; and (3) percentage and dollar amount of the total costs of the project or program that will be financed by nongovernmental sources. Condition: The Organization did not include required language in its communications surrounding federally funded projects as required by the Health Resources and Services Administration Grants Policy Bulletin Legislative Mandates in Grants Management for FY2022. Cause: The Organization was aware of the annual Bulletin, but as many of the other aspects did not apply, they overlooked the required federal funding language in the contract selected for testing. Effect: The Organization may not be eligible for future funding or might have to pay back federal funds received for costs not appropriately documented to support compliance with the HRSA Annual Grants Policy Bulletin requirements for federally funded projects. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: Include language in the Organization's Grant Management Policy to include aspects of the Annual Policy Bulletin to ensure those in charge of communication are aware of the annual updates and requirements associated with projects funded with federal dollars View of Responsible Officials: Management agrees with the finding and will update the Grant Management Policy to include the applicable aspects of the Annual Policy Bulletin.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.
Finding 2022-003
2022-003 – Cash Management Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Management is responsible for establishing and maintaining effective internal control over the advance payment requests related to federal awards. Condition: The Organization was unable to provide documentation to support the advanced draw calculation estimate or its approval by someone other than the individual who requested the draw for 3 of the 11 selections tested. Cause: The Organization does not have a consistent process in place to estimate the amount of advance draws for a 30-day period of needed funding, nor do they have a consistent process in place for the documentation of the review/approval of the advance draw by someone other than the individual who requests the funds. Effect: The Organization could advance draw an amount greater than their need for a 30-day period, or staff could request funds without the proper approval. Questioned Costs: $100,000 Recommendation: The Organization should develop a clearly documented process and method to determine the amount of advance draw not to exceed a 30-day need. This process should include appropriate review, approval and documentation of the advance draw prior to requesting the funds. View of Responsible Officials: Management agrees with the finding and will develop a process and method to determine the appropriate calculation for the advance draw process including the proper review and approvals.