Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-001: Financial Reporting – Material Weakness, is also considered a finding under Federal Award Findings and Questioned Costs. This finding is applicable to all federal programs.
Criteria
An accounting system and effective internal control environment should support the preparation of the financial statements in accordance with Generally Accepted Accounting Principles (“GAAP”) and grant reports in accordance with Federal and State compliance requirements, including a robust financial close process at year end.
Condition
In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules.
Cause
The Organization experienced staffing shortages and related difficulties during the fiscal year.
Effect
The books and records were not closed and finalized until many months after year end.
Context
The Organization’s accounting processes and internal controls over financial reporting were not functioning properly.
Recommendation
We recommend that the Organization maintain appropriately trained and experienced personnel. This will help ensure that the accounting processes and internal controls over financial reporting will function properly, and that the financial close process will be complete, accurate, and timely.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-002: Reporting and Annual Audit Submission – Significant Deficiency
Assistance Listing Program Title and Number: All
Federal Agency: All
Criteria
As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. The Organization is also required to submit periodic reports under the terms and conditions of its federal award contracts
Condition
The audit, Data Collection Form and reporting package were not submitted by the due date March 31, 2024. The Organization submitted reports that did not reconcile to the accounting records, and were not submitted by the due date.
Cause
The Organization was not able to timely prepare for the audit in order for the Uniform Guidance, Data Collection Form and reporting package to be filed by the due date. The Organization’s reporting of charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that the reports reconcile to the expenditures charged to the federal award.
Effect
The audit, Data Collection Form and federal reporting package were not filed on time. Certain periodic reports did not reconcile to the general ledger. The Health Center Program required a reclassifying adjustment of $357,849 of expenditures between grant contracts. Ryan White required a reclassifying adjustment $599,717 of expenditures between grant contracts. The support for the allocations was not available as noted in finding 2023-003, therefore it is not known whether the reports contained unallowable costs or whether the costs were improperly recorded on the general ledger.
Questioned Costs
Unknown
Context
The Organization was unable to complete the financial statements and Federal Single Audit by the due date. The support used to reconcile the general ledger to the grant reports filed was not provided nor could the support be regenerated from the accounting system. The allocations made to the grants were not available or identified for testing.
Recommendation
We recommend that all necessary efforts be taken to ensure timely submission of the audit, Data Collection Form and reporting package. We recommend reports be reconciled to the accounting records prior to their submission. Sufficient internal controls should be designed and implemented to detect and prevent errors in reports and within the accounting system. We also recommend all necessary efforts be taken to ensure timely submission.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 establishes cost principles for determining costs applicable to federal awards. These principles include the requirement that cost allocation methodologies be reasonable and documented and that all expenses charged to federal awards are appropriately supported. The cost allocations should be reviewed and updated for changes to operations.
Condition
The Organization was unable to produce documentation supporting its cost allocation plan (“CAP”). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records.
Cause
The Organization was unable to produce support for the allocation of costs to federal awards. The CAP has not been updated regularly.
Effect
The basis for computing and allocating costs to federal awards according to the CAP is unsupported.
Questioned Costs
Unknown.
Context
The Organization is unable to document the basis for allocating costs to its federal awards.
Recommendation
We recommend that the Organization document its basis for allocating costs to federal awards, and that the supporting documentation and related reconciliations be retained, in accordance with the Uniform Guidance. The CAP should be reviewed periodically and updated for changes in operations as deemed necessary, and approved by the Board of Directors.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.
Finding No. 2023-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness
Federal Program Name: All
Pass-through Entity: All
Federal Assistance Listing Number: All
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 includes the requirement that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives.
Condition
The Organization was unable to produce records supporting the work performed or support the distribution of wages.
Cause
The Organization’s charges to federal awards for salaries and wages are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and that reasonably reflect the total activity for which the employee is compensated.
Effect
The basis for allocating costs to federal awards is unsupported by documentation.
Questioned Costs
Unknown.
Context
There is no support, such as a time sheet or personnel activity report, for the allocation of wages charged to federal awards.
Recommendation
We recommend that the Organization develop, implement and maintain a system of internal controls to support the proper tracking and allocation of wages to federal awards.
Management’s Response/View of Responsible Officials
Management agrees with this finding, see the Corrective Action Plan.