Audit 399222

2025-001: ACTIVITIES ALLOWED/ALLOWABLE COSTS - DIRECT COSTS Type: Considered a significant deficiency in internal control over compliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: As detailed by 2 CFR 200.402, “the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits”. Condition: Expenditures charged to the grant were not authorized in the grant budget. Cause/Effect: Management oversight. Questioned Cost: Below the reporting threshold. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that only allowable costs are charged to the grant. Management’s Resp: Management is in agreement with this recommendation.

2025-002: ACTIVITIES ALLOWED/ALLOWABLE COSTS – INDIRECT COSTS Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR requirements, and the grant budget, modified total direct costs must exclude the portion of each subaward or contract in excess of $25,000. Condition: The CMHSP included all contract costs, including amounts over $25,000, in the modified total direct costs. Cause/Effect: Management oversight. Questioned Cost: Below the reporting threshold. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that amounts used to calculate indirect costs charged to the grant properly exclude contract amounts over the allowed limit. Management’s Resp: Management is in agreement with this recommendation.

2025-003: PROCUREMENT - SUSPENSION AND DEBARMENT Type: Considered a significant deficiency in internal control over compliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Cause/Effect: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.