Audit 403483

Federal Agency: United States Department of Health and Human Services Federal Programs: Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.696 Federal Award Year: 2024-2025 Criteria or Specific Requirement – Level of effort (2 CFR § 200.430) includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non-federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non-federal funding of services. Condition – The Corporation failed to meet the 80% level of effort requirements as stipulated in the grant agreements. Cause – The Corporation lacked adequate controls and procedures to support personnel costs charged to the grant, including maintaining time studies or equivalent documentation to substantiate the level of effort, as required by Uniform Guidance (2 CFR § 200.430). Effect or Potential Effect – Failure to allocate payroll costs for employees with required level of- effort commitments may result in noncompliance with grant requirements. Questioned Costs – None Context – We selected a sample of one individual out of a population of five individuals for testing. For the individual selected, the Corporation was unable to provide evidence the specified level of service to be provided was met. As a result, level of effort activities were not completed in accordance with federal regulations nor was supporting documentation retained to demonstrate compliance. The sampling methodology used is not, and is not intended to be, statistically valid. Identification as a Repeat Finding – No Recommendation – The Corporation should establish and maintain internal controls over compliance with level of effort requirements, including documenting employee time through timesheets that accurately allocate time charged to the grant in accordance with applicable grant requirements. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding. Arisa’s time-keeping application is designed to meet FLSA recordkeeping requirements. This system does not contain a solution to subdivide hours worked by project in a manner that would satisfy level of effort reporting. Arisa will require employees in positions that are partially or fully funded through a federal contract containing level of effort requirements to complete and submit a separate paper timesheet documenting time worked on the federal contract. In addition, subcontractors will be required to include a certification on their invoices that applicable level of effort requirements were met.

Federal Agency: United States Department of Health and Human Services Federal Programs: Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.696 Federal Award Year: 2024-2025 Criteria or Specific Requirement – Suspension and debarment (2 CFR 180) Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Corporation did not have adequate controls and procedures in place relating to suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – The Corporation may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – We selected a sample of one vendor out of a population of two vendors for testing. For the vendor selected, the Corporation was unable to provide evidence the covered transaction was not with a vendor suspended, debarred, or otherwise excluded. As a result, suspension and debarment activities were not completed in accordance with federal regulations nor was supporting documentation retained to demonstrate compliance. The sampling methodology used is not, and is not intended to be, statistically valid. Identification as a Repeat Finding – No Recommendation – The Corporation should incorporate internal controls over compliance with the suspension and debarment compliance requirement including monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding. Arisa has subsequently received a signed certification from the subcontractor dated 4/20/2026 indicating that the vendor was not debarred, suspended, or otherwise excluded from participation in federal assistance programs. For future federal awards, Arisa will collect a certification from the subcontractor/vendor indicating compliance with this requirement.