Block Grants for Prevention and
Treatment of Substance Abuse
ALN No. 93.959
U.S. Department of Health and Human Services
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed and Unallowed and
Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2
CFR sections 200.308, 200.309, and 200.403(h)
Condition – A sample of 80 expenditures were selected from each of the
following populations:
• ALN No. 93.959 – 1,839 items totaling $1,243,944
• ALN No. 93.788 – 1,502 items totaling $2,285,983
The samples were not, and are not intended to be, statistically valid. Of
the 80 expenditures tested from each grant program, the following were
determined to lack appropriate supporting documentation to support
being charged to grant program:
• ALN No. 93.959 - 51 items totaling $26,145, including projected
errors over the total population totaling $348,063
• ALN No. 93.788 - 6 items totaling $18,183, including projected
errors over the total population totaling $165,074
The Organization did not have adequate supporting documentation
demonstrating actual time and effort reporting and lacked evidence of
supporting invoices.
Cause – The Organization charged budgeted percentages to the
grant programs without a system in place to monitor and track that actual
time and effort was consistent with budgeted percentages. In addition, the
Organization charged expenditures to the grant programs without evidence of
supporting invoices.
Effect or potential effect – Costs charged to the grant programs could have
varied from actual time and effort. In addition, costs charged to the grant
could not be supported by actual invoices.
Questioned costs –
• ALN No. 93.959 - $26,145
• ALN No. 93.788 - $18,183
Context – The Organization did not have a reasonable methodology of
allocating costs to these grant programs and did not maintain proper
supporting invoices.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should implement policies and
procedures that strengthen internal control over compliance in relation to
activities allowed and cost principles. The policy and procedure should
be designed to ensure that a reasonable allocation methodology is
implemented and followed or that time and effort is certified by the
employee on a regular basis. In addition, management should implement a
document retention policy consistent with 2 CFR 200.334.
Block Grants for Prevention and
Treatment of Substance Abuse
ALN No. 93.959
U.S. Department of Health and Human Services
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed and Unallowed and
Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2
CFR sections 200.308, 200.309, and 200.403(h)
Condition – A sample of 80 expenditures were selected from each of the
following populations:
• ALN No. 93.959 – 1,839 items totaling $1,243,944
• ALN No. 93.788 – 1,502 items totaling $2,285,983
The samples were not, and are not intended to be, statistically valid. Of
the 80 expenditures tested from each grant program, the following were
determined to lack appropriate supporting documentation to support
being charged to grant program:
• ALN No. 93.959 - 51 items totaling $26,145, including projected
errors over the total population totaling $348,063
• ALN No. 93.788 - 6 items totaling $18,183, including projected
errors over the total population totaling $165,074
The Organization did not have adequate supporting documentation
demonstrating actual time and effort reporting and lacked evidence of
supporting invoices.
Cause – The Organization charged budgeted percentages to the
grant programs without a system in place to monitor and track that actual
time and effort was consistent with budgeted percentages. In addition, the
Organization charged expenditures to the grant programs without evidence of
supporting invoices.
Effect or potential effect – Costs charged to the grant programs could have
varied from actual time and effort. In addition, costs charged to the grant
could not be supported by actual invoices.
Questioned costs –
• ALN No. 93.959 - $26,145
• ALN No. 93.788 - $18,183
Context – The Organization did not have a reasonable methodology of
allocating costs to these grant programs and did not maintain proper
supporting invoices.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should implement policies and
procedures that strengthen internal control over compliance in relation to
activities allowed and cost principles. The policy and procedure should
be designed to ensure that a reasonable allocation methodology is
implemented and followed or that time and effort is certified by the
employee on a regular basis. In addition, management should implement a
document retention policy consistent with 2 CFR 200.334.
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Procurement, Suspension and Debarment
– 45 CFR 75.329, 2 CFR 180
Condition – For procurement testing, a sample of 3 procurements was
selected from a population of 12 totaling $537,276. For suspension and
department testing, a sample of 2 was selected from a population of 7 totaling
$469,071. The samples were not, and are not intended to be, statistically
valid. Of the samples tested, the following were determined to lack
appropriate supporting documentation for compliance requirement:
• Procurement: 3 items totaling $216,847, including projected errors
over the total population totaling $537,276
• Suspension and debarment: 2 items totaling $157,617, including
projected errors over the total population totaling $469,071
Procurement procedures were not followed for vendors with greater than
$10,000 in purchases of goods or services charged to the federal award. In
addition, the Organization does not have adequate policies governing
suspension and debarment requirements for the purchase of goods or services
charged to federal awards. Specifically, the Organization did not verify that
vendors were not suspended, debarred, or otherwise excluded.
Cause – The Organization did not comply with their procurement policy. In
addition, the Organization does not include a review of the federal suspended
and debarment party list as part of the Organization's procurement policy.
Effect or potential effect – Procurement methodology was not followed for
vendor with expenses of over $10,000. In addition, that did not adhere to the
federal government's suspension and debarment compliance requirements.
Questioned Costs – None
Context – The Organization did not have adequate policies and procedures to
ensure procurement, suspension, and debarment requirements were met prior
to the purchase of goods or services charged to federal awards. Upon further discussion with Tuerk House, Inc., no procurement, suspension and debarment procedures were performed on any vendors.
Identification as a repeat finding – Not a repeat finding
Recommendation – We recommend management continue to ensure all
personnel understand the procurement policy and adhere to the requirements
and guidelines set forth in the policy. Procedures should be implemented to
ensure that vendors, especially those over $10,000, are selected and vetted in
accordance with policy and Uniform Guidance. In addition, policies and
procedures should be put in place to ensure all vendors are not included on
the suspended and debarred listing.
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Reporting (45 CFR 75.342)
Condition – The Organization’s annual expenditure reporting did not agree to
the underlying grant expenditure support. In addition, the Organization did
not properly report certain information in its quarterly programmatic reports.
Cause – The Organization did not have necessary internal controls to
properly identify and report eligible grant expenditures. In addition, the
Organization did not have controls in place to support amounts reported in
quarterly programmatic reporting requirements.
Effect or potential effect– The Organization incorrectly reported grant
expenditures and programmatic statistics, such as total unique patients.
Questioned Costs – None
Context – A sample of one financial report was tested out of the total
population of 2 financial reports. In addition, a sample of one special report
was tested out of the total population of 4 special reports. The sampling
methodology used is not and is not intended to be statistically valid. Certain
amounts on the financial and special reports were not accurately reported.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should review the required reports for
accuracy prior to submission to ensure the documentation supports the
amounts in the report.
COVID-19 Provider Relief Fund and
American Rescue (ARP) Rural Distribution
ALN No. 93.498
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed or Unallowed and Allowable
Costs/Cost Principles (Pub. L. No. 116- 136, 134 Stat. 563 and Pub. L. No. 116-
139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342)
Condition – The Organization was required to file a Period 2 and Period 3
Provider Relief Fund (PRF) reports during the year; however, did not
maintain adequate documentation to support the other PRF expenses were
attributable to coronavirus and/or had not been or were not eligible to be
reimbursed by other sources.
Questioned Costs – $261,607 calculated as the PRF amounts received by the
Organization and included in Period 2 and Period 3 reporting.
Context – The Organization was unable to provide adequate documentation
to support the other PRF expenses had not been or were not eligible to be
reimbursed by other sources.
Effect – The Organization utilized PRF payments received on expenses that
were not documented as attributable to coronavirus, were potentially
reimbursed by other sources, and/or were not allowable in accordance with
other guidance issued by HHS.
Cause – Provider Relief Fund and American Rescue Plan (ARP) Rural
Distribution is a new program with complex and evolving regulations and
compliance requirements. Internal controls were not in place to ensure the
Organization correctly applied the guidance.
Identification as a repeat finding – Not a repeat finding
Recommendation – Policies and procedures over allowable activities and
federal grant reporting should be modified to ensure expenditures charged to
grants are for activities allowed and federal grant reports are prepared using
complete and accurate information.
Block Grants for Prevention and
Treatment of Substance Abuse
ALN No. 93.959
U.S. Department of Health and Human Services
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed and Unallowed and
Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2
CFR sections 200.308, 200.309, and 200.403(h)
Condition – A sample of 80 expenditures were selected from each of the
following populations:
• ALN No. 93.959 – 1,839 items totaling $1,243,944
• ALN No. 93.788 – 1,502 items totaling $2,285,983
The samples were not, and are not intended to be, statistically valid. Of
the 80 expenditures tested from each grant program, the following were
determined to lack appropriate supporting documentation to support
being charged to grant program:
• ALN No. 93.959 - 51 items totaling $26,145, including projected
errors over the total population totaling $348,063
• ALN No. 93.788 - 6 items totaling $18,183, including projected
errors over the total population totaling $165,074
The Organization did not have adequate supporting documentation
demonstrating actual time and effort reporting and lacked evidence of
supporting invoices.
Cause – The Organization charged budgeted percentages to the
grant programs without a system in place to monitor and track that actual
time and effort was consistent with budgeted percentages. In addition, the
Organization charged expenditures to the grant programs without evidence of
supporting invoices.
Effect or potential effect – Costs charged to the grant programs could have
varied from actual time and effort. In addition, costs charged to the grant
could not be supported by actual invoices.
Questioned costs –
• ALN No. 93.959 - $26,145
• ALN No. 93.788 - $18,183
Context – The Organization did not have a reasonable methodology of
allocating costs to these grant programs and did not maintain proper
supporting invoices.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should implement policies and
procedures that strengthen internal control over compliance in relation to
activities allowed and cost principles. The policy and procedure should
be designed to ensure that a reasonable allocation methodology is
implemented and followed or that time and effort is certified by the
employee on a regular basis. In addition, management should implement a
document retention policy consistent with 2 CFR 200.334.
Block Grants for Prevention and
Treatment of Substance Abuse
ALN No. 93.959
U.S. Department of Health and Human Services
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed and Unallowed and
Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2
CFR sections 200.308, 200.309, and 200.403(h)
Condition – A sample of 80 expenditures were selected from each of the
following populations:
• ALN No. 93.959 – 1,839 items totaling $1,243,944
• ALN No. 93.788 – 1,502 items totaling $2,285,983
The samples were not, and are not intended to be, statistically valid. Of
the 80 expenditures tested from each grant program, the following were
determined to lack appropriate supporting documentation to support
being charged to grant program:
• ALN No. 93.959 - 51 items totaling $26,145, including projected
errors over the total population totaling $348,063
• ALN No. 93.788 - 6 items totaling $18,183, including projected
errors over the total population totaling $165,074
The Organization did not have adequate supporting documentation
demonstrating actual time and effort reporting and lacked evidence of
supporting invoices.
Cause – The Organization charged budgeted percentages to the
grant programs without a system in place to monitor and track that actual
time and effort was consistent with budgeted percentages. In addition, the
Organization charged expenditures to the grant programs without evidence of
supporting invoices.
Effect or potential effect – Costs charged to the grant programs could have
varied from actual time and effort. In addition, costs charged to the grant
could not be supported by actual invoices.
Questioned costs –
• ALN No. 93.959 - $26,145
• ALN No. 93.788 - $18,183
Context – The Organization did not have a reasonable methodology of
allocating costs to these grant programs and did not maintain proper
supporting invoices.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should implement policies and
procedures that strengthen internal control over compliance in relation to
activities allowed and cost principles. The policy and procedure should
be designed to ensure that a reasonable allocation methodology is
implemented and followed or that time and effort is certified by the
employee on a regular basis. In addition, management should implement a
document retention policy consistent with 2 CFR 200.334.
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Procurement, Suspension and Debarment
– 45 CFR 75.329, 2 CFR 180
Condition – For procurement testing, a sample of 3 procurements was
selected from a population of 12 totaling $537,276. For suspension and
department testing, a sample of 2 was selected from a population of 7 totaling
$469,071. The samples were not, and are not intended to be, statistically
valid. Of the samples tested, the following were determined to lack
appropriate supporting documentation for compliance requirement:
• Procurement: 3 items totaling $216,847, including projected errors
over the total population totaling $537,276
• Suspension and debarment: 2 items totaling $157,617, including
projected errors over the total population totaling $469,071
Procurement procedures were not followed for vendors with greater than
$10,000 in purchases of goods or services charged to the federal award. In
addition, the Organization does not have adequate policies governing
suspension and debarment requirements for the purchase of goods or services
charged to federal awards. Specifically, the Organization did not verify that
vendors were not suspended, debarred, or otherwise excluded.
Cause – The Organization did not comply with their procurement policy. In
addition, the Organization does not include a review of the federal suspended
and debarment party list as part of the Organization's procurement policy.
Effect or potential effect – Procurement methodology was not followed for
vendor with expenses of over $10,000. In addition, that did not adhere to the
federal government's suspension and debarment compliance requirements.
Questioned Costs – None
Context – The Organization did not have adequate policies and procedures to
ensure procurement, suspension, and debarment requirements were met prior
to the purchase of goods or services charged to federal awards. Upon further discussion with Tuerk House, Inc., no procurement, suspension and debarment procedures were performed on any vendors.
Identification as a repeat finding – Not a repeat finding
Recommendation – We recommend management continue to ensure all
personnel understand the procurement policy and adhere to the requirements
and guidelines set forth in the policy. Procedures should be implemented to
ensure that vendors, especially those over $10,000, are selected and vetted in
accordance with policy and Uniform Guidance. In addition, policies and
procedures should be put in place to ensure all vendors are not included on
the suspended and debarred listing.
Opioid STR
ALN No. 93.788
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Reporting (45 CFR 75.342)
Condition – The Organization’s annual expenditure reporting did not agree to
the underlying grant expenditure support. In addition, the Organization did
not properly report certain information in its quarterly programmatic reports.
Cause – The Organization did not have necessary internal controls to
properly identify and report eligible grant expenditures. In addition, the
Organization did not have controls in place to support amounts reported in
quarterly programmatic reporting requirements.
Effect or potential effect– The Organization incorrectly reported grant
expenditures and programmatic statistics, such as total unique patients.
Questioned Costs – None
Context – A sample of one financial report was tested out of the total
population of 2 financial reports. In addition, a sample of one special report
was tested out of the total population of 4 special reports. The sampling
methodology used is not and is not intended to be statistically valid. Certain
amounts on the financial and special reports were not accurately reported.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – Management should review the required reports for
accuracy prior to submission to ensure the documentation supports the
amounts in the report.
COVID-19 Provider Relief Fund and
American Rescue (ARP) Rural Distribution
ALN No. 93.498
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed or Unallowed and Allowable
Costs/Cost Principles (Pub. L. No. 116- 136, 134 Stat. 563 and Pub. L. No. 116-
139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342)
Condition – The Organization was required to file a Period 2 and Period 3
Provider Relief Fund (PRF) reports during the year; however, did not
maintain adequate documentation to support the other PRF expenses were
attributable to coronavirus and/or had not been or were not eligible to be
reimbursed by other sources.
Questioned Costs – $261,607 calculated as the PRF amounts received by the
Organization and included in Period 2 and Period 3 reporting.
Context – The Organization was unable to provide adequate documentation
to support the other PRF expenses had not been or were not eligible to be
reimbursed by other sources.
Effect – The Organization utilized PRF payments received on expenses that
were not documented as attributable to coronavirus, were potentially
reimbursed by other sources, and/or were not allowable in accordance with
other guidance issued by HHS.
Cause – Provider Relief Fund and American Rescue Plan (ARP) Rural
Distribution is a new program with complex and evolving regulations and
compliance requirements. Internal controls were not in place to ensure the
Organization correctly applied the guidance.
Identification as a repeat finding – Not a repeat finding
Recommendation – Policies and procedures over allowable activities and
federal grant reporting should be modified to ensure expenditures charged to
grants are for activities allowed and federal grant reports are prepared using
complete and accurate information.