Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.