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 – 1,152 items totaling $1,077,416
• ALN No. 93.788 – 1,222 items totaling $2,537,080
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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145
• ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012
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 - $25,810
• ALN No. 93.788 - $72,347
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 – Repeat finding (see 2023-003)
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 – 1,152 items totaling $1,077,416
• ALN No. 93.788 – 1,222 items totaling $2,537,080
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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145
• ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012
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 - $25,810
• ALN No. 93.788 - $72,347
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 – Repeat finding (see 2023-003)
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 1 procurement was selected from a population of 5 totaling $487,910. For suspension and department testing, a sample of 1 was selected from a population of 3 totaling $464,333. 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: 1 item totaling $59,791, including projected errors over the total population totaling $487,910
• Suspension and debarment: 1 item totaling $59,791, including projected errors over the total population totaling $464,333
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 – Repeat finding (see 2022-004 and 2023-004)
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 – Repeat finding (see 2022-005 and 2023-005)
Recommendation – Management should review the required reports for accuracy prior to submission to ensure the documentation supports the amounts in the report.
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 – 1,152 items totaling $1,077,416
• ALN No. 93.788 – 1,222 items totaling $2,537,080
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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145
• ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012
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 - $25,810
• ALN No. 93.788 - $72,347
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 – Repeat finding (see 2023-003)
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 – 1,152 items totaling $1,077,416
• ALN No. 93.788 – 1,222 items totaling $2,537,080
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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145
• ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012
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 - $25,810
• ALN No. 93.788 - $72,347
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 – Repeat finding (see 2023-003)
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 1 procurement was selected from a population of 5 totaling $487,910. For suspension and department testing, a sample of 1 was selected from a population of 3 totaling $464,333. 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: 1 item totaling $59,791, including projected errors over the total population totaling $487,910
• Suspension and debarment: 1 item totaling $59,791, including projected errors over the total population totaling $464,333
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 – Repeat finding (see 2022-004 and 2023-004)
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 – Repeat finding (see 2022-005 and 2023-005)
Recommendation – Management should review the required reports for accuracy prior to submission to ensure the documentation supports the amounts in the report.