Audit 308831

Finding No. 2022-008: Late Filing of Data Collection Form – Material Weakness – Internal Control and Compliance Finding Criteria In accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition There are inadequate internal controls in place to ensure that HealthHIV financial statement audit is completed in a manner to allow the Data Collection Form to be filed by the reporting deadline. Context The Data Collection Form for the year ended December 31, 2022 was not submitted to the Federal Audit Clearinghouse by the September 30, 2023 deadline. Cause There were delays in completing the 2022 audit as management needed additional time to reconcile accounts and provide the requested supporting documentation due to employee turnover. Effect Management did not fully adhere to the requirements of the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-006. Recommendation We recommend that management enhance its internal controls, policies and procedures to ensure that all filing requirements under federal awards are met. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-009: Improper Procurement Processes and Controls – Material Weakness – Internal Control and Compliance Finding ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2022 ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 Criteria For acquisitions exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by HealthHIV. If the procurement is sole sourced, adequate written justification for noncompetitive procurement is required. In addition, HealthHIV should verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System maintained by the General Services Administration, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition and Context HealthHIV did not have adequate internal controls in place over procurement. As a result, there was no documentation to support the rationale for selection of six vendors for ALN 93.136 and two vendors for ALN 93.834 during the year. In addition, the suspension and debarment checks for the six vendors for ALN 93.136 and two vendors for ALN 93.834 were also not performed before entering into contract with the vendors. Cause Employee turnover during the year resulted in documents being misplaced or not properly prepared. Effect HealthHIV did not fully adhere to federal laws and regulations. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-007. Recommendation We recommend that HealthHIV implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-010: Allowable Cost and Cost Principles – Material Weakness – Internal Control and Compliance Finding ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2024 Findings 2022-004 and 2022-007 are also findings for the federal award programs as they impacted the expenses charged to the federal awards. For ALN 93.834, there was an instance in which an expense for $18,430 was recorded in 2022, when the service was provided only in 2023. Thus, the expenses reported for ALN 93.834 were overstated by $18,430 before any adjustment were made to correct the overstatement. For ALN 93.136, there were duplicate consulting expenses totaling $66,854 that were charged and billed twice to the program in 2021. Thus, the expenses reported for ALN 93.136 in 2021 were overstated by $66,854, which is considered a questioned cost.

Finding No. 2022-008: Late Filing of Data Collection Form – Material Weakness – Internal Control and Compliance Finding Criteria In accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition There are inadequate internal controls in place to ensure that HealthHIV financial statement audit is completed in a manner to allow the Data Collection Form to be filed by the reporting deadline. Context The Data Collection Form for the year ended December 31, 2022 was not submitted to the Federal Audit Clearinghouse by the September 30, 2023 deadline. Cause There were delays in completing the 2022 audit as management needed additional time to reconcile accounts and provide the requested supporting documentation due to employee turnover. Effect Management did not fully adhere to the requirements of the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-006. Recommendation We recommend that management enhance its internal controls, policies and procedures to ensure that all filing requirements under federal awards are met. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-009: Improper Procurement Processes and Controls – Material Weakness – Internal Control and Compliance Finding ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2022 ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 Criteria For acquisitions exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by HealthHIV. If the procurement is sole sourced, adequate written justification for noncompetitive procurement is required. In addition, HealthHIV should verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System maintained by the General Services Administration, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition and Context HealthHIV did not have adequate internal controls in place over procurement. As a result, there was no documentation to support the rationale for selection of six vendors for ALN 93.136 and two vendors for ALN 93.834 during the year. In addition, the suspension and debarment checks for the six vendors for ALN 93.136 and two vendors for ALN 93.834 were also not performed before entering into contract with the vendors. Cause Employee turnover during the year resulted in documents being misplaced or not properly prepared. Effect HealthHIV did not fully adhere to federal laws and regulations. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-007. Recommendation We recommend that HealthHIV implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-010: Allowable Cost and Cost Principles – Material Weakness – Internal Control and Compliance Finding ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2024 Findings 2022-004 and 2022-007 are also findings for the federal award programs as they impacted the expenses charged to the federal awards. For ALN 93.834, there was an instance in which an expense for $18,430 was recorded in 2022, when the service was provided only in 2023. Thus, the expenses reported for ALN 93.834 were overstated by $18,430 before any adjustment were made to correct the overstatement. For ALN 93.136, there were duplicate consulting expenses totaling $66,854 that were charged and billed twice to the program in 2021. Thus, the expenses reported for ALN 93.136 in 2021 were overstated by $66,854, which is considered a questioned cost.

Finding No. 2022-008: Late Filing of Data Collection Form – Material Weakness – Internal Control and Compliance Finding Criteria In accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition There are inadequate internal controls in place to ensure that HealthHIV financial statement audit is completed in a manner to allow the Data Collection Form to be filed by the reporting deadline. Context The Data Collection Form for the year ended December 31, 2022 was not submitted to the Federal Audit Clearinghouse by the September 30, 2023 deadline. Cause There were delays in completing the 2022 audit as management needed additional time to reconcile accounts and provide the requested supporting documentation due to employee turnover. Effect Management did not fully adhere to the requirements of the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-006. Recommendation We recommend that management enhance its internal controls, policies and procedures to ensure that all filing requirements under federal awards are met. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-009: Improper Procurement Processes and Controls – Material Weakness – Internal Control and Compliance Finding ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2022 ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 Criteria For acquisitions exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by HealthHIV. If the procurement is sole sourced, adequate written justification for noncompetitive procurement is required. In addition, HealthHIV should verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System maintained by the General Services Administration, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition and Context HealthHIV did not have adequate internal controls in place over procurement. As a result, there was no documentation to support the rationale for selection of six vendors for ALN 93.136 and two vendors for ALN 93.834 during the year. In addition, the suspension and debarment checks for the six vendors for ALN 93.136 and two vendors for ALN 93.834 were also not performed before entering into contract with the vendors. Cause Employee turnover during the year resulted in documents being misplaced or not properly prepared. Effect HealthHIV did not fully adhere to federal laws and regulations. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-007. Recommendation We recommend that HealthHIV implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-010: Allowable Cost and Cost Principles – Material Weakness – Internal Control and Compliance Finding ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2024 Findings 2022-004 and 2022-007 are also findings for the federal award programs as they impacted the expenses charged to the federal awards. For ALN 93.834, there was an instance in which an expense for $18,430 was recorded in 2022, when the service was provided only in 2023. Thus, the expenses reported for ALN 93.834 were overstated by $18,430 before any adjustment were made to correct the overstatement. For ALN 93.136, there were duplicate consulting expenses totaling $66,854 that were charged and billed twice to the program in 2021. Thus, the expenses reported for ALN 93.136 in 2021 were overstated by $66,854, which is considered a questioned cost.

Finding No. 2022-008: Late Filing of Data Collection Form – Material Weakness – Internal Control and Compliance Finding Criteria In accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition There are inadequate internal controls in place to ensure that HealthHIV financial statement audit is completed in a manner to allow the Data Collection Form to be filed by the reporting deadline. Context The Data Collection Form for the year ended December 31, 2022 was not submitted to the Federal Audit Clearinghouse by the September 30, 2023 deadline. Cause There were delays in completing the 2022 audit as management needed additional time to reconcile accounts and provide the requested supporting documentation due to employee turnover. Effect Management did not fully adhere to the requirements of the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-006. Recommendation We recommend that management enhance its internal controls, policies and procedures to ensure that all filing requirements under federal awards are met. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-009: Improper Procurement Processes and Controls – Material Weakness – Internal Control and Compliance Finding ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2022 ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 Criteria For acquisitions exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by HealthHIV. If the procurement is sole sourced, adequate written justification for noncompetitive procurement is required. In addition, HealthHIV should verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System maintained by the General Services Administration, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition and Context HealthHIV did not have adequate internal controls in place over procurement. As a result, there was no documentation to support the rationale for selection of six vendors for ALN 93.136 and two vendors for ALN 93.834 during the year. In addition, the suspension and debarment checks for the six vendors for ALN 93.136 and two vendors for ALN 93.834 were also not performed before entering into contract with the vendors. Cause Employee turnover during the year resulted in documents being misplaced or not properly prepared. Effect HealthHIV did not fully adhere to federal laws and regulations. Questioned Costs None. Repeat Finding Yes. This was reported as Finding 2021-007. Recommendation We recommend that HealthHIV implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Finding No. 2022-010: Allowable Cost and Cost Principles – Material Weakness – Internal Control and Compliance Finding ALN 93.834 – Capacity Building Assistance for High Impact HIV; Grant Number 5NU65PS923684-04-00; Grant Period: April 1, 2019 to March 31, 2024 ALN 93.136 – Injury Prevention and Control Research and State and Community Based Programs; Grant Number HAHSTA2020-000017; Grant Period: July 1, 2020 to August 31, 2024 Findings 2022-004 and 2022-007 are also findings for the federal award programs as they impacted the expenses charged to the federal awards. For ALN 93.834, there was an instance in which an expense for $18,430 was recorded in 2022, when the service was provided only in 2023. Thus, the expenses reported for ALN 93.834 were overstated by $18,430 before any adjustment were made to correct the overstatement. For ALN 93.136, there were duplicate consulting expenses totaling $66,854 that were charged and billed twice to the program in 2021. Thus, the expenses reported for ALN 93.136 in 2021 were overstated by $66,854, which is considered a questioned cost.