Activities Allowed or Unallowed
Allowable Costs and Cost Principles
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: The funds are to be used primarily to support direct treatment services for individuals impacted by the COVID-19 pandemic. No more than 15 percent of the total grant award for each budget period may be used for data collection, performance measurement, and performance assessment, including incentives for participating in the required data collection follow-up. Up to $25,000 of the annual grant award for each budget period may be used to purchase technical assistance. If technical assistance is not needed, the recipient may use those funds for allowable or required activities.
Condition: The Center was unable to provide support demonstrating the tracking and internal controls used to monitor the 15 percent requirement and the $25,000 technical assistance limit requirement. The Center supplied prepared financial statements for each quarter, which supported the amounts claimed as used with these funds. However, transaction detail of what made up these totals could not be provided.
Context: There are two 12-month incremental periods in this award; the first restricts the recipient from spending more than $2,000,000 from 2/15/2021 to 2/14/2022, and the second period is also limited to $2,000,000 for the period covering 2/15/2022 to 2/14/2023. Staff prepared financial statements for each quarter that showed total income received and expenses incurred for the program.
Effect: We were unable to determine if the Center complied with the 15 percent requirement or the $25,000 technical assistance limit. We were also unable to test a sample of direct costs charged to the program since transaction details supporting the prepared financial statements were not provided.
Questioned Costs: We were unable to determine if there were any questioned costs.
Cause: The Center has financial statements and spreadsheets showing what costs were attributable to this program, but we were not provided with information showing the tracking of these requirements or details of these costs. Staff responsible for tracking this information are no longer employed with the Center.
Auditor Recommendation: We recommend that the Center implement procedures to adequately retain supporting documents for federal programs.
Organization Response: The Staff Accountant will retain in hard copy and/or electronic form all supporting documentation of costs attributable to the CCBHC grant. Electronic records of grant transactions will be kept on CFMH one drive cloud, and printed copies will be kept in a grant folder. This includes but is not limited to all requests and approvals of expenditures, drawdowns, and any funding revisions and approvals. The supporting documents substantiating specific revenue and expense detail for the transactions will be uploaded and attached to the specific journal entry in Intacct. It will be the responsibility of the Accounting Manager (or Controller in the absence of the Accounting Manager) to monitor compliance with the retention of all supporting documentation by the Staff Accountant. The Accounting Manager (or Controller in the absence of the Accounting Manager) will be responsible for tracking and monitoring that no more than 15% of the total grant award for each budget period will be used for costs related to data collection, performance measurement, and performance assessment. The Accounting Manager (or Controller in the absence of the Accounting Manager) will also be responsible for tracking and monitoring that no more than $25,000 of the annual grant award for each budget period may be used for costs related to the purchase of technical assistance. The Center for Mental Health policies and procedures have been updated to include this additional level of accountability and internal control.
Cash Management
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award.
Condition: The Center has spreadsheets and financial statements supporting the amounts drawn during the year for this award; however, there was no indication that requests for reimbursements were reviewed or authorized prior to submission.
Context: There were four draws made during the fiscal year for this award, totaling $2,410,670. For one draw, funds were drawn in advance of costs incurred, totaling $368,286. For the remaining three, funds were drawn on a reimbursement basis after costs were incurred.
Effect: There is an increased risk of errors in draw amounts if internal controls are not in place.
Questioned Costs: No questioned costs.
Cause: Primarily, one staff member was responsible for the cash draws.
Auditor Recommendation: We recommend that the Center establish policies and procedures for cash management over federal funds, implement internal controls over cash management, and retain documentation for these controls.
Organization Response: Requests for cost reimbursements (drawdowns) from federal funds will be requested by the Accounting Manager (or Controller in the absence of the Accounting Manager) and reviewed and authorized by the Controller (or CFO in the absence of the Controller) prior to submission of the drawdown. Once the drawdown has been approved by the Controller (or CFO in the absence of the Controller), then the Accounting Manager submits the drawdown request for funds. In the absence of the Accounting Manager to submit the drawdown request, the Controller initiates the drawdown request, the CFO reviews and approves the request, and the Controller submits the drawdown request. Supporting documentation for cost reimbursement (drawdowns) will be maintained by the Controller (or CFO in the absence of the Controller) and the Staff Accountant and Accounting Manager will also retain any supporting documentation related to the drawdown of federal funds. The Center for Mental Health policy and procedure for cash management of federal funds has been updated to include this additional level of control.
Reporting
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award.
Condition: The Center completed programmatic reports as required in the grant award. However, there was no evidence that these reports were reviewed or authorized prior to submission.
Context: There were two programmatic reports submitted during the audit period, and we tested one of the reports.
Effect: There is an increased risk of errors or omissions in the programmatic reports.
Questioned Costs: No questioned costs.
Cause: Center staff stated the information was prepared by an employee and reviewed by another. However, no documentation was retained indicating the programmatic report was reviewed prior to submission.
Auditor Recommendation: We recommend that the Center establish policies and procedures for reporting and retain documentation for these controls.
Organization Response: The preparation of programmatic reports for federal funds will be the responsibility of the Staff Accountant. Any completed programmatic reports will then be reviewed by the Accounting Manager (or Controller in the absence of the Accounting Manager) and the grant Program Director (PD) and authorized by the Controller (or CFO in the absence of the Controller) prior to submission. Electronic and/or printed copies of written communications related to the review and approval of programmatic reports will be secured in a grant folder in the CFMH Microsoft Outlook email system and/or the Microsoft Teams application, or in a physical grants folder maintained by the Staff Accountant. The Controller (or CFO in the absence of the Controller) will have the responsibility to retain records pertaining to the communication demonstrating the review and approval of prepared programmatic reposts for federal grant funding. The Staff Accountant and the Accounting Manager will also retain any supporting documents related to communication of the review and approval process for programmatic reports for federal grant funding.
Activities Allowed or Unallowed
Allowable Costs and Cost Principles
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: The funds are to be used primarily to support direct treatment services for individuals impacted by the COVID-19 pandemic. No more than 15 percent of the total grant award for each budget period may be used for data collection, performance measurement, and performance assessment, including incentives for participating in the required data collection follow-up. Up to $25,000 of the annual grant award for each budget period may be used to purchase technical assistance. If technical assistance is not needed, the recipient may use those funds for allowable or required activities.
Condition: The Center was unable to provide support demonstrating the tracking and internal controls used to monitor the 15 percent requirement and the $25,000 technical assistance limit requirement. The Center supplied prepared financial statements for each quarter, which supported the amounts claimed as used with these funds. However, transaction detail of what made up these totals could not be provided.
Context: There are two 12-month incremental periods in this award; the first restricts the recipient from spending more than $2,000,000 from 2/15/2021 to 2/14/2022, and the second period is also limited to $2,000,000 for the period covering 2/15/2022 to 2/14/2023. Staff prepared financial statements for each quarter that showed total income received and expenses incurred for the program.
Effect: We were unable to determine if the Center complied with the 15 percent requirement or the $25,000 technical assistance limit. We were also unable to test a sample of direct costs charged to the program since transaction details supporting the prepared financial statements were not provided.
Questioned Costs: We were unable to determine if there were any questioned costs.
Cause: The Center has financial statements and spreadsheets showing what costs were attributable to this program, but we were not provided with information showing the tracking of these requirements or details of these costs. Staff responsible for tracking this information are no longer employed with the Center.
Auditor Recommendation: We recommend that the Center implement procedures to adequately retain supporting documents for federal programs.
Organization Response: The Staff Accountant will retain in hard copy and/or electronic form all supporting documentation of costs attributable to the CCBHC grant. Electronic records of grant transactions will be kept on CFMH one drive cloud, and printed copies will be kept in a grant folder. This includes but is not limited to all requests and approvals of expenditures, drawdowns, and any funding revisions and approvals. The supporting documents substantiating specific revenue and expense detail for the transactions will be uploaded and attached to the specific journal entry in Intacct. It will be the responsibility of the Accounting Manager (or Controller in the absence of the Accounting Manager) to monitor compliance with the retention of all supporting documentation by the Staff Accountant. The Accounting Manager (or Controller in the absence of the Accounting Manager) will be responsible for tracking and monitoring that no more than 15% of the total grant award for each budget period will be used for costs related to data collection, performance measurement, and performance assessment. The Accounting Manager (or Controller in the absence of the Accounting Manager) will also be responsible for tracking and monitoring that no more than $25,000 of the annual grant award for each budget period may be used for costs related to the purchase of technical assistance. The Center for Mental Health policies and procedures have been updated to include this additional level of accountability and internal control.
Cash Management
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award.
Condition: The Center has spreadsheets and financial statements supporting the amounts drawn during the year for this award; however, there was no indication that requests for reimbursements were reviewed or authorized prior to submission.
Context: There were four draws made during the fiscal year for this award, totaling $2,410,670. For one draw, funds were drawn in advance of costs incurred, totaling $368,286. For the remaining three, funds were drawn on a reimbursement basis after costs were incurred.
Effect: There is an increased risk of errors in draw amounts if internal controls are not in place.
Questioned Costs: No questioned costs.
Cause: Primarily, one staff member was responsible for the cash draws.
Auditor Recommendation: We recommend that the Center establish policies and procedures for cash management over federal funds, implement internal controls over cash management, and retain documentation for these controls.
Organization Response: Requests for cost reimbursements (drawdowns) from federal funds will be requested by the Accounting Manager (or Controller in the absence of the Accounting Manager) and reviewed and authorized by the Controller (or CFO in the absence of the Controller) prior to submission of the drawdown. Once the drawdown has been approved by the Controller (or CFO in the absence of the Controller), then the Accounting Manager submits the drawdown request for funds. In the absence of the Accounting Manager to submit the drawdown request, the Controller initiates the drawdown request, the CFO reviews and approves the request, and the Controller submits the drawdown request. Supporting documentation for cost reimbursement (drawdowns) will be maintained by the Controller (or CFO in the absence of the Controller) and the Staff Accountant and Accounting Manager will also retain any supporting documentation related to the drawdown of federal funds. The Center for Mental Health policy and procedure for cash management of federal funds has been updated to include this additional level of control.
Reporting
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: Entities receiving federal awards shall establish and maintain internal control over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award.
Condition: The Center completed programmatic reports as required in the grant award. However, there was no evidence that these reports were reviewed or authorized prior to submission.
Context: There were two programmatic reports submitted during the audit period, and we tested one of the reports.
Effect: There is an increased risk of errors or omissions in the programmatic reports.
Questioned Costs: No questioned costs.
Cause: Center staff stated the information was prepared by an employee and reviewed by another. However, no documentation was retained indicating the programmatic report was reviewed prior to submission.
Auditor Recommendation: We recommend that the Center establish policies and procedures for reporting and retain documentation for these controls.
Organization Response: The preparation of programmatic reports for federal funds will be the responsibility of the Staff Accountant. Any completed programmatic reports will then be reviewed by the Accounting Manager (or Controller in the absence of the Accounting Manager) and the grant Program Director (PD) and authorized by the Controller (or CFO in the absence of the Controller) prior to submission. Electronic and/or printed copies of written communications related to the review and approval of programmatic reports will be secured in a grant folder in the CFMH Microsoft Outlook email system and/or the Microsoft Teams application, or in a physical grants folder maintained by the Staff Accountant. The Controller (or CFO in the absence of the Controller) will have the responsibility to retain records pertaining to the communication demonstrating the review and approval of prepared programmatic reposts for federal grant funding. The Staff Accountant and the Accounting Manager will also retain any supporting documents related to communication of the review and approval process for programmatic reports for federal grant funding.