Audit 413926

Reporting (Significant Deficiency) Criteria: The subaward agreements require GNHP to submit quarterly financial reports and quarterly reports that include a comparison of actual expenditures to budgeted expenditures and a written narrative performance report describing accomplishments resulting from the expenditure of Coronavirus State and Local Fiscal Recovery Funds (“SLFRF”). GNHP is responsible for complying with the reporting requirements established by the applicable subaward agreements and federal requirements. Condition: During our testing of GNHP's compliance with reporting requirements for the SLFRF program, we noted that GNHP did not consistently prepare, review, and/or submit the required financial and performance reports in accordance with the requirements of the subaward agreements. Effect: Failure to prepare and submit required reports accurately and timely may result in noncompliance with the terms and conditions of the SLFRF subawards and may prevent the pass-through entity from obtaining the information necessary to monitor the use and performance of federal funds. Continued noncompliance could also result in additional monitoring, withholding of funds, or other remedies available to the pass-through entity. Cause: GNHP did not have formalized policies and procedures establishing the nature, timing, extent, and documentation requirements for reporting of federal awards. Recommendation: We recommend that GNHP establish formal procedures for monitoring SLFRF reporting requirements and deadlines. Such procedures should require reconciliation of reported financial information to the general ledger and supporting records, documented management review of financial and performance information, and retention of evidence demonstrating the date and manner in which each required report was submitted to the pass-through entities. Views of the Responsible Official: See attached Corrective Action Plan

Subrecipient Monitoring (Significant Deficiency) Criteria: A pass-through entity is required to monitor the activities of its subrecipients as necessary to ensure that federal awards are used for authorized purposes, in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward, and that applicable performance goals are achieved. The 2025 Compliance Supplement identifies Subrecipient Monitoring as a compliance requirement subject to audit. Condition: GNHP awarded SLFRF funds to downstream subrecipients associated with the Horizon Heights and St. Michael's Monastery projects. During our testing, we noted that GNHP did not adequately document that it performed the required monitoring of these subrecipients. Specifically, sufficient documentation was not available to demonstrate systematic review of the subrecipients' financial and performance information, use of SLFRF funds, compliance with applicable federal requirements and subaward terms, and follow-up of identified compliance matters. Effect: Without adequate and documented subrecipient monitoring, GNHP may not timely identify instances in which federal funds are used for unauthorized purposes or in violation of federal requirements or subaward terms. As a result, there is an increased risk that subrecipient noncompliance or questioned costs could occur and remain undetected. Cause: GNHP did not have formalized policies and procedures establishing the nature, timing, extent, and documentation requirements for monitoring downstream subrecipients of federal awards. Recommendation: We recommend that GNHP establish and implement formal subrecipient monitoring procedures consistent with applicable federal requirements. The procedures should include identifying and documenting each subrecipient relationship, communicating applicable federal award requirements, evaluating subrecipient risk, determining the appropriate nature and extent of monitoring, periodically reviewing financial and performance information and supporting documentation, documenting monitoring activities performed, and following up on identified deficiencies or noncompliance until corrective action has been completed. Views of the Responsible Official: See attached Corrective Action Plan.