Criteria: Nonfederal 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. Condition: GLIDE did not maintain formal evidence of review and approval of contracts subject to procurement standards. In addition, GLIDE did not have a procurement policy in place that conformed to the federal procurement requirements. Questioned Costs: There were no questioned costs identified.Recommendation: Update the written procurement policy to align with applicable federal requirements, train responsible personnel, and require a complete procurement file for each covered purchase, including the procurement method, quotes or bids as applicable, evaluation and selection rationale, conflict-of-interest considerations, and evidence of approval. Repeat finding: This is not a repeat finding. Context: We obtained a population of contracts exceeding $10,000 and selected two of the four contracts for testing, totaling $97,430. GLIDE provided supporting documentation demonstrating that multiple bids were obtained and evaluated for the contracts selected. However, management was unable to provide documentation evidencing the formal review and approval of contracts subject to procurement standards. Cause: Procurement controls were not effectively designed and implemented. Management did not ensure that procurement procedures were aligned with federal requirements or that supporting documentation to evidence review and approval was retained in the procurement file. Effect: Without documentation of approval, GLIDE cannot demonstrate controls were operating effectively to ensure compliance with federal procurement standards, including full and open competition and required procurement history documentation.
Criteria: GLIDE’s award terms for Federal Award No. CE1HS52473 required submission of an annual Federal Financial Report (FFR/SF-425) within 90 calendar days after the end of the budget period. This requirement is consistent with 45 CFR 75.302(a)(2), 75.303, and 75.341 (current 2 CFR 200.302(b)(2), 200.303, and 200.328), which require financial management systems and internal controls sufficient to permit accurate, current, and complete reporting and timely submission of required federal financial reports in accordance with award terms. Condition: For the budget period ended September 29, 2024, the annual FFR was due December 28, 2024. Management submitted the report on January 30, 2025, which was 33 days after the due date Questioned Costs: There were no questioned costs identified. Context: The exception related to the annual FFR tested for this direct HHS award and indicates that report due dates were not effectively tracked and monitored for timely submission. Cause: Controls over tracking award-specific reporting deadlines, preparing the annual FFR, and ensuring timely management review and submission were not operating effectively. Effect: Late submission of required financial reports constitutes noncompliance with award terms and increases the risk of delayed grantor monitoring, delayed payment processing, or other follow-up by the awarding agency. Recommendation: Establish a reporting calendar by award and budget period, assign responsibility for preparation and review of each FFR, require documented supervisory review before submission, and retain evidence of submission and any approved extensions. Repeat finding: This is not a repeat finding.
Criteria: The 2 CFR Section 200 §303 requires that non-Federal entities receiving Federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Related to these requirements, Glide Foundation should submit drawdown requests to the Department of Health and Human Services throughout the fiscal year as costs are incurred and Federal Financial Reports should agree with those drawdown requests and supporting accounting records. Condition: We noted that for the reimbursement request submitted on January 28, 2025, management did not retain evidence to support the review and approval of the reimbursement request prior to submission.Recommendation: Establish written procedures requiring reconciliation of each reimbursement request to the general ledger and supporting invoices, payroll, or other source records; retain evidence of review and approval; and submit requests on a timely basis for actual allowable costs incurred. Repeat finding: This is not a repeat finding. Questioned Costs: There were no questioned costs identified. Context: We tested one reimbursement requests totaling $259,886 submitted during the fiscal year for the Department of Health and Human Services award and an exception. The exception indicates that the control requiring documented supervisory review over reimbursement requests was not consistently operating throughout the audit period. We noted there was only one reimbursement request submitted for award CE1HS52473 in 2025. Cause: Documented review procedures for reimbursement requests were not consistently implemented, and supervisory oversight over the reimbursement process was insufficient. Effect: Without documented review and approval, GLIDE cannot demonstrate that reimbursement requests were complete, accurate, supported by underlying records, and submitted in accordance with award requirements. This increases the risk of inaccurate financial reporting and unsupported reimbursement requests.
Criteria: GLIDE was required to submit financial and programmatic reports in accordance with the reporting terms in its subaward agreements with Sierra Health Foundation. Based on the agreements provided, required submissions included quarterly and cumulative reports with due dates specified by the pass-through entity, including a July 18, 2025 due date for certain required submissions and a July 30, 2025 due date for the final cumulative financial report under CA23BHR0433/B08T1083929. Condition: For grant agreement CA24CMP1514, the final cumulative report was submitted on November 4, 2025, after the stated July 18, 2025 due date. For grant agreement CA23BHR0433/B08T1083929, the Q2 2025 report was submitted on August 21, 2025, after the stated July 18, 2025 due date. In addition, management did not maintain evidence supporting the preparation, review, and submission of the final cumulative report for the period December 1, 2023 through June 30, 2025 under CA23BHR0433/B08T1083929. Questioned Costs: There were no questioned costs identified. Context: Across the two subaward agreements tested, we examined both final cumulative reports and three of the eight quarterly reports submitted. Two instances of late reporting were identified, and supporting documentation was not retained for one of the final cumulative reports. Cause: Controls over tracking reporting deadlines, preparing reports, and retaining evidence of review and submission were not operating effectively. Effect: Late submission of required financial reports constitutes noncompliance with award terms and increases the risk of delayed grantor monitoring, delayed payment processing, or other follow-up by the awarding agency. Recommendation: Establish a reporting calendar by award, assign responsibility for preparation and review, maintain evidence of management review and submission for each required report, and periodically reconcile submitted reports to the underlying accounting records and supporting documentation. Repeat finding: This is not a repeat finding.
Criteria: The 2 CFR Section 200 §303 requires that non-Federal entities receiving Federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Related to these requirements, Glide Foundation should submit drawdown requests to the Department of Health and Human Services throughout the fiscal year as costs are incurred and Federal Financial Reports should agree with those drawdown requests and supporting accounting records. Condition: We noted that for the reimbursement requests submitted on November 30, 2024 and June 30, 2025, management did not retain evidence of review and approval prior to submission. Questioned Costs: There were no questioned costs identified. Context: We obtained a reporting listing the invoices submitted for reimbursement and reconciled the total amount to the schedule of expenditures of federal and state awards. We selected four of 17 invoices, totaling $44,427. The exception related to the reimbursement submissions tested for this award and indicates that documented supervisory review was not consistently operating over reimbursement requests. Cause: Documented review procedures for reimbursement requests were not consistently implemented, and supervisory oversight over the reimbursement process was insufficient. Effect: Without documented review and approval, GLIDE cannot demonstrate that reimbursement requests were complete, accurate, supported by underlying records, and submitted in accordance with award requirements. This increases the risk of inaccurate financial reporting and unsupported reimbursement requests.Recommendation: Establish written procedures requiring reconciliation of each reimbursement request to the general ledger and supporting invoices, payroll, or other source records; retain evidence of review and approval; and submit requests on a timely basis for actual allowable costs incurred. Repeat finding: This is not a repeat finding.