Finding 2024-004 – PROCUREMENT (repeat finding)
Type: Material Weakness in Internal Control/Noncompliance.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, formal procurement methods are required.
Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified.”
Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant.
Cause: This condition was caused by an insufficient internal control process for procurement including 1) requirement/review and approval of formal bid, and 2) review for suspension and debarment.
Effect: The CMHSP purchased several items pursuant to a contract that did not go through a formal bid process or have evidence of review for suspension and debarment.
Questioned Cost: $340,014
Context: One contract was paid from grant funds. The questioned cost shown above reflects the amount paid from grant funds for the year pursuant to this contract which did not go through a formal bid process or have evidence of review for suspension and debarment. Upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that procurements adhere to the requirements of 2 CFR 200.
Management’s Resp: We are in agreement with this finding.
Finding 2024-005 – REPORTING (repeat finding)
Type: Material Weakness in Internal Control/Noncompliance.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.328(c), “The recipient or subrecipient must submit financial reports as required by the Federal award.” According to the closeout requirements of the Federal award, recipients must, “Reconcile financial expenditures to the reported total disbursement and charges in PMS.”
Condition: The CMHSP did not file the required annual Federal Financial Report as required for this grant.
Cause: This condition was caused by an insufficient internal control process for grant reporting.
Effect: Reporting requirements required by the grant were not met.
Questioned Cost: None.
Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the CMHSP’s internal records. However, the final report of expenses was never submitted.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports are filed in accordance with the grant requirements.
Management’s Resp: We are in agreement with this finding.
Finding 2024-006 – CASH MANAGEMENT (repeat comment)
Type: Significant Deficiency in Internal Control.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.303, recipients must, “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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).”
Condition: The CMHSP has established internal controls relating to approvals of cash requests. However, during testing, we noted that cash requests did not contain evidence of required review and approvals.
Cause: This condition was caused by an insufficient internal control process for review and approval of cash requests.
Effect: Cash requests submitted prior to review and approval are at risk of reporting incorrect information.
Questioned Cost: None.
Context: Although amounts listed in the cash requests were supported by the CMHSP’s internal records, the requests did not contain evidence of approvals.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that cash requests are reviewed and approved prior to submission.
Management’s Resp: We are in agreement with this finding.
Finding 2024-007 – CASH MANAGEMENT
Type: Significant Deficiency in Internal Control.
Program: ALN 93.958 Block Grants for Community Mental Health Services
Grant Name: COVID 19 - BH Workforce Stabilization Fund - ARPA
Grantor Number: E20240268-00
Criteria: Pursuant to IV.C. of the grant agreement, “…FSRs must be submitted on a monthly basis, no later than 30 days after the close of each calendar month. The Monthly FSRs must reflect total actual program expenditures, up to the total agreement amount.”
Condition: The CMHSP did file FSRs for reimbursement. However, during testing it was noted that expenses listed in 1 of the 4 monthly FSRs tested were not supported by the CMHSP’s internal records.
Cause: This condition was caused by an insufficient internal control process for cash management.
Effect: Requirements for reimbursement pursuant to the grant document were not met.
Questioned Cost: None.
Context: Amounts received as Federal reimbursement for 1 of 4 months were not supported by the CMHSP’s internal records. However, the final report of expenses for this grant did agree with the CMHSP’s annual expenses.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that expenses listed in reports are supported by the CMHSP’s internal records.
Management’s Resp: We are in agreement with this finding.
Finding 2024-004 – PROCUREMENT (repeat finding)
Type: Material Weakness in Internal Control/Noncompliance.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, formal procurement methods are required.
Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified.”
Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant.
Cause: This condition was caused by an insufficient internal control process for procurement including 1) requirement/review and approval of formal bid, and 2) review for suspension and debarment.
Effect: The CMHSP purchased several items pursuant to a contract that did not go through a formal bid process or have evidence of review for suspension and debarment.
Questioned Cost: $340,014
Context: One contract was paid from grant funds. The questioned cost shown above reflects the amount paid from grant funds for the year pursuant to this contract which did not go through a formal bid process or have evidence of review for suspension and debarment. Upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that procurements adhere to the requirements of 2 CFR 200.
Management’s Resp: We are in agreement with this finding.
Finding 2024-005 – REPORTING (repeat finding)
Type: Material Weakness in Internal Control/Noncompliance.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.328(c), “The recipient or subrecipient must submit financial reports as required by the Federal award.” According to the closeout requirements of the Federal award, recipients must, “Reconcile financial expenditures to the reported total disbursement and charges in PMS.”
Condition: The CMHSP did not file the required annual Federal Financial Report as required for this grant.
Cause: This condition was caused by an insufficient internal control process for grant reporting.
Effect: Reporting requirements required by the grant were not met.
Questioned Cost: None.
Context: Amounts received as Federal reimbursement, as detailed in PMS, were supported by the CMHSP’s internal records. However, the final report of expenses was never submitted.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that reports are filed in accordance with the grant requirements.
Management’s Resp: We are in agreement with this finding.
Finding 2024-006 – CASH MANAGEMENT (repeat comment)
Type: Significant Deficiency in Internal Control.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.303, recipients must, “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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).”
Condition: The CMHSP has established internal controls relating to approvals of cash requests. However, during testing, we noted that cash requests did not contain evidence of required review and approvals.
Cause: This condition was caused by an insufficient internal control process for review and approval of cash requests.
Effect: Cash requests submitted prior to review and approval are at risk of reporting incorrect information.
Questioned Cost: None.
Context: Although amounts listed in the cash requests were supported by the CMHSP’s internal records, the requests did not contain evidence of approvals.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that cash requests are reviewed and approved prior to submission.
Management’s Resp: We are in agreement with this finding.
Finding 2024-007 – CASH MANAGEMENT
Type: Significant Deficiency in Internal Control.
Program: ALN 93.958 Block Grants for Community Mental Health Services
Grant Name: COVID 19 - BH Workforce Stabilization Fund - ARPA
Grantor Number: E20240268-00
Criteria: Pursuant to IV.C. of the grant agreement, “…FSRs must be submitted on a monthly basis, no later than 30 days after the close of each calendar month. The Monthly FSRs must reflect total actual program expenditures, up to the total agreement amount.”
Condition: The CMHSP did file FSRs for reimbursement. However, during testing it was noted that expenses listed in 1 of the 4 monthly FSRs tested were not supported by the CMHSP’s internal records.
Cause: This condition was caused by an insufficient internal control process for cash management.
Effect: Requirements for reimbursement pursuant to the grant document were not met.
Questioned Cost: None.
Context: Amounts received as Federal reimbursement for 1 of 4 months were not supported by the CMHSP’s internal records. However, the final report of expenses for this grant did agree with the CMHSP’s annual expenses.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that expenses listed in reports are supported by the CMHSP’s internal records.
Management’s Resp: We are in agreement with this finding.