Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 Criteria: Reporting ? The Federal Funding and Transparency Act (FFATA) requires recipients of non-Recovery Act funded grants and cooperative agreements to report subawards of $30,000 or more. Condition and context: Change Happens did not file the required FFATA reporting for the 7 subawards over $30,000. Repeat of finding #2021-010 for the 2021 major program, Assistance Listing #93.092. Cause: The Corrective Action Plan for finding #2021-010 was not implemented for this program. Effect: Non-compliance with federal reporting requirements. Questioned costs: None Recommendation: Develop a process for FFATA reporting to ensure timely reporting for all federal programs, where applicable, and provide training to personnel regarding FFATA reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 Criteria: Reporting ? The Federal Funding and Transparency Act (FFATA) requires recipients of non-Recovery Act funded grants and cooperative agreements to report subawards of $30,000 or more. Condition and context: Change Happens did not file the required FFATA reporting for the 7 subawards over $30,000. Repeat of finding #2021-010 for the 2021 major program, Assistance Listing #93.092. Cause: The Corrective Action Plan for finding #2021-010 was not implemented for this program. Effect: Non-compliance with federal reporting requirements. Questioned costs: None Recommendation: Develop a process for FFATA reporting to ensure timely reporting for all federal programs, where applicable, and provide training to personnel regarding FFATA reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.