2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.