Finding Number: 2024-004
Agency: Department of Health & Human Services
Federal Program: Immunization Cooperative Agreement
ALN: 93.268
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials
Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287
Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-004
Agency: Department of Health & Human Services
Federal Program: Immunization Cooperative Agreement
ALN: 93.268
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials
Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287
Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006
Agency: Department of Health & Human Services
Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases
ALN: 93.323
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121
Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006
Agency: Department of Health & Human Services
Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases
ALN: 93.323
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121
Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-003
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grants to the States
ALN: 93.994
Compliance Requirement: Earmarking
Category: Material Weakness in Internal Control over Compliance
Criteria
45 CFR sections 92.20(a) and (b) (1) to (4) establish that:
a) A State must expend and account for grant funds in accordance with State laws and procedures for expending and accounting for its own funds. Fiscal control and accounting procedures of the State, as well as its subgrantees and cost-type contractors, must be enough to,
1.
Permit preparation of reports required by this part and the statutes authorizing the grant, and
2.
Permit the tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes.
b) The financial management systems of other grantees and subgrantees must meet the following standards:
1.
Financial reporting. Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant.
2.
Budget control. Actual expenditures or outlays must be compared with budgeted amounts for each grant or subgrant. Financial information must be related to performance or productivity data, including the development of unit cost information whenever appropriate or specifically required in the grant or subgrant agreement. if unit cost data are required, estimates based on available documentation will be accepted whenever possible. Condition
We noted the following deficiencies related to the grant awards B04MC47443:
a.
The PRDH does not segregate financial records sufficiently in order to permit the tracing of funds to a level of expenditures adequate to establish that such funds have not been used in violation of the percentage restrictions of the grant award.
b.
We could not evaluate if the program is in compliance with the established earmarking requirements since the expenses were recorded for each of the award components and not the earmarking activity.
Cause
This situation occurs because the accounting records currently used by the PRDH do not have a reliable system to account for funds awarded to them. The chart of accounts in the financial system is not sufficiently expanded to account for each of the earmark requirements.
Effect
The PRDH could exceed the established expenditures limits per activity for the grant award. Noncompliance with the earmarking requirements could lead to significant administrative sanctions by the grantor, including reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve program objectives.
Questioned Costs
None
Perspective Information
Finding represents a significant problem. The agency will review internal controls to ensure that comply with federal government requirements.
Prior Year Audit Finding
2023-004
Recommendation
The PRDH must expand the chart of accounts in order to account for the amounts claimed for administrative expenditures independently. This expansion would permit the tracing of funds to a level of expenditure to establish that such funds have not been used in violation of the restrictions and prohibitions of the program as defined in 42 USC 705(a)(3). Also, payroll expenses must be recorded into each of the corresponding program activities, as follows: a)
Preventive and primary care services for children.
b)
Services for children with special health care needs.
Views of Responsible Officials
PRDOH agrees with the finding. PRDOH has fixed the segregation of financial record, we already have the system in place in People Soft 8.4 in which permit the tracing of the funds to the level of expenditures that will be adequate.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551
Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimate Date of Completion
The process is in place for the grants that start for the fiscal year 2024-2025.
Finding Number: 2024-005
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grant to the State
ALN: 93.994
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Maternal and Child Health Services Block Grant to the State, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551 Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-007
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grant to the State
ALN: 93.994
Grant Number: 23B04MC47443
Compliance Requirement: Reporting
Category: Material Weakness on Internal Control and Noncompliance
Criteria
2 CFR Part 200 Section 328 established unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.
2 CFR Part 200 Section 303 states that the entity must be established and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.
Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.
Condition
We could not observe the SF-425 reports for the grant 23B04MC47443. According to the program accountant, the SF-425 report for the current period was due on December 30, 2024, as specified in the Notice of Award. The program requested a waiver to submit the report on January 31, 2025. The Department of Health's Office of External Resources submitted the request through the Payment Management System on January 9, 2025. As of now, the federal government has not responded to this waiver request.
Cause
The PRDH has not established effective procedures for the timely filing of the required financial reports.
Effect
The PRDH is not in compliance with the federal regulations on reporting. The inaccurate and untimely reporting prevents the Federal awarding agency and PRDF’s management from monitoring the program financial activities, assessing the achievements of the program, and evaluating the grant award for subsequent years.
Questioned Costs
None
Perspective Information
As part of our audit procedures over reporting requirements, we evaluated Federal Financial Reports (SF-425) for the quarter ended on July 31, 2024. The test revealed that the report was not in compliance.
Prior Year Audit Finding
None
Recommendation
Management should take appropriate actions to implement internal controls procedures should be enforced to ascertain that required reports are timely filed; otherwise, a waiver or extension of time must be obtained.
Views of responsible officials
PRDH agrees with the finding. In this case there were three (3) more reports submitted for extension to the federal government, however, with this particular report the PRDH did not receive an answer. However, we have procedures in place in order to meet the reporting requirements to all federal programs be submitted on time.
The PRDH is working with the Division of External Resources (Federal Program) to establish and strengthen our internal controls to ensure all federal reports comply with the guidelines established by the Federal Government.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551
Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimated Completion Date
Estimated date of completion immediately.
Finding Number: 2024-004
Agency: Department of Health & Human Services
Federal Program: Immunization Cooperative Agreement
ALN: 93.268
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials
Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287
Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-004
Agency: Department of Health & Human Services
Federal Program: Immunization Cooperative Agreement
ALN: 93.268
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of twenty-five (25) cash drawdown petitions for the Immunization Cooperative Agreement, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made. Responsible Officials
Mrs. Camille Francisco Peguero Program Accountant 787-765-2929 ext. 3287
Dr. Angel M. Rivera Garcia Program Director 787-765-2929 ext. 3338
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006
Agency: Department of Health & Human Services
Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases
ALN: 93.323
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121
Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-006
Agency: Department of Health & Human Services
Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases
ALN: 93.323
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written internal procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121
Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-003
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grants to the States
ALN: 93.994
Compliance Requirement: Earmarking
Category: Material Weakness in Internal Control over Compliance
Criteria
45 CFR sections 92.20(a) and (b) (1) to (4) establish that:
a) A State must expend and account for grant funds in accordance with State laws and procedures for expending and accounting for its own funds. Fiscal control and accounting procedures of the State, as well as its subgrantees and cost-type contractors, must be enough to,
1.
Permit preparation of reports required by this part and the statutes authorizing the grant, and
2.
Permit the tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the restrictions and prohibitions of applicable statutes.
b) The financial management systems of other grantees and subgrantees must meet the following standards:
1.
Financial reporting. Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant.
2.
Budget control. Actual expenditures or outlays must be compared with budgeted amounts for each grant or subgrant. Financial information must be related to performance or productivity data, including the development of unit cost information whenever appropriate or specifically required in the grant or subgrant agreement. if unit cost data are required, estimates based on available documentation will be accepted whenever possible. Condition
We noted the following deficiencies related to the grant awards B04MC47443:
a.
The PRDH does not segregate financial records sufficiently in order to permit the tracing of funds to a level of expenditures adequate to establish that such funds have not been used in violation of the percentage restrictions of the grant award.
b.
We could not evaluate if the program is in compliance with the established earmarking requirements since the expenses were recorded for each of the award components and not the earmarking activity.
Cause
This situation occurs because the accounting records currently used by the PRDH do not have a reliable system to account for funds awarded to them. The chart of accounts in the financial system is not sufficiently expanded to account for each of the earmark requirements.
Effect
The PRDH could exceed the established expenditures limits per activity for the grant award. Noncompliance with the earmarking requirements could lead to significant administrative sanctions by the grantor, including reduction in the amounts to be awarded. It could also be interpreted as a failure to achieve program objectives.
Questioned Costs
None
Perspective Information
Finding represents a significant problem. The agency will review internal controls to ensure that comply with federal government requirements.
Prior Year Audit Finding
2023-004
Recommendation
The PRDH must expand the chart of accounts in order to account for the amounts claimed for administrative expenditures independently. This expansion would permit the tracing of funds to a level of expenditure to establish that such funds have not been used in violation of the restrictions and prohibitions of the program as defined in 42 USC 705(a)(3). Also, payroll expenses must be recorded into each of the corresponding program activities, as follows: a)
Preventive and primary care services for children.
b)
Services for children with special health care needs.
Views of Responsible Officials
PRDOH agrees with the finding. PRDOH has fixed the segregation of financial record, we already have the system in place in People Soft 8.4 in which permit the tracing of the funds to the level of expenditures that will be adequate.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551
Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimate Date of Completion
The process is in place for the grants that start for the fiscal year 2024-2025.
Finding Number: 2024-005
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grant to the State
ALN: 93.994
Grant Number: Various
Compliance Requirement: Cash Management
Category: Significant Deficiency in Internal Control over Compliance
Criteria
2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Condition
During our procedures, we found the following exceptions:
a) In a sample of fifteen (25) cash drawdown petitions for Maternal and Child Health Services Block Grant to the State, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request. Cause
Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis.
Effect
Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions.
Questioned Costs
None
Perspective Information
Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe.
Prior Year Audit Finding
None
Recommendation
The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds.
Views of responsible officials
The PRDOH is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, the PRDOH is working and verifying our own written procedures to ensure that payments are issued promptly after the drawdown is made.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551 Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimated Completion Date
The Completion date for the revised procedures will be by December 2025.
Finding Number: 2024-007
Agency: Department of Health & Human Services
Federal Program: Maternal and Child Health Services Block Grant to the State
ALN: 93.994
Grant Number: 23B04MC47443
Compliance Requirement: Reporting
Category: Material Weakness on Internal Control and Noncompliance
Criteria
2 CFR Part 200 Section 328 established unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.
2 CFR Part 200 Section 303 states that the entity must be established and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.
Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality.
Condition
We could not observe the SF-425 reports for the grant 23B04MC47443. According to the program accountant, the SF-425 report for the current period was due on December 30, 2024, as specified in the Notice of Award. The program requested a waiver to submit the report on January 31, 2025. The Department of Health's Office of External Resources submitted the request through the Payment Management System on January 9, 2025. As of now, the federal government has not responded to this waiver request.
Cause
The PRDH has not established effective procedures for the timely filing of the required financial reports.
Effect
The PRDH is not in compliance with the federal regulations on reporting. The inaccurate and untimely reporting prevents the Federal awarding agency and PRDF’s management from monitoring the program financial activities, assessing the achievements of the program, and evaluating the grant award for subsequent years.
Questioned Costs
None
Perspective Information
As part of our audit procedures over reporting requirements, we evaluated Federal Financial Reports (SF-425) for the quarter ended on July 31, 2024. The test revealed that the report was not in compliance.
Prior Year Audit Finding
None
Recommendation
Management should take appropriate actions to implement internal controls procedures should be enforced to ascertain that required reports are timely filed; otherwise, a waiver or extension of time must be obtained.
Views of responsible officials
PRDH agrees with the finding. In this case there were three (3) more reports submitted for extension to the federal government, however, with this particular report the PRDH did not receive an answer. However, we have procedures in place in order to meet the reporting requirements to all federal programs be submitted on time.
The PRDH is working with the Division of External Resources (Federal Program) to establish and strengthen our internal controls to ensure all federal reports comply with the guidelines established by the Federal Government.
Responsible Officials
Dr. Manuel Vargas Bernier Program Director 787-765-2929 ext. 4583
Mrs. Diana Ferrer Rivera Senior Accountant 787-765-2929 ext. 4551
Mrs. Lydia Magaly Cabrera Accountant 787-765-2929 ext. 4587
Estimated Completion Date
Estimated date of completion immediately.