Audit 405959

2025-001: ACTIVITIES ALLOWED OR UNALLOWED/ALLOWABLE COST PRINCIPLES Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.696 - Certified Community Behavioral Health Clinic Expansion Grants; Grant Number H79SM087001-01 ALN 93.788 - Opioid STR; Grant Number H79TI087831 Criteria: As detailed by 2 CFR 200.430(g)(1)(vii), “Budget estimates (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (C) The recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: During testing, it was noted that payroll was allocated to the grants based on budget estimates because the payroll system used did not allow staff to document their hours across multiple programs in real-time. However, after-the-fact reviews of charges made to the Federal awards were not done to ensure that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Cause/Effect: This condition appears to be the result of a misunderstanding of personal services documentation requirements. Questioned Cost: Indeterminable Recommendation: We recommend that the CMHSP review payroll procedures to ensure that after-the-fact reviews of payroll allocations are performed to support the assertion that final payroll amounts charged to the Federal award are accurate, allowable, and properly allocated.