Audit 50495

FY End
2022-09-30
Total Expended
$6.87M
Findings
22
Programs
1
Organization: Integral Global Health, Inc. (GA)
Year: 2022 Accepted: 2023-06-29
Auditor: Grace CPAS LLC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
44079 2022-001 Material Weakness - L
44080 2022-002 - - I
44081 2022-003 - - C
44082 2022-004 - - L
44083 2022-001 Material Weakness - L
44084 2022-002 - - I
44085 2022-003 - - C
44086 2022-004 - - L
44087 2022-002 - - I
44088 2022-003 - - C
44089 2022-004 - - L
620521 2022-001 Material Weakness - L
620522 2022-002 - - I
620523 2022-003 - - C
620524 2022-004 - - L
620525 2022-001 Material Weakness - L
620526 2022-002 - - I
620527 2022-003 - - C
620528 2022-004 - - L
620529 2022-002 - - I
620530 2022-003 - - C
620531 2022-004 - - L

Contacts

Name Title Type
Y2KNANNC9FK5 Mamoon Munir Auditee
6785800853 Andrew Tregembo Auditor
No contacts on file

Notes to SEFA

Accounting Policies: Note 1:Basis of PresentationThe accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Integral Global Health, Inc. (the Corporation) under programs of the federal government for the year ended September 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Corporation, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Corporation. Note 2:Summary of Significant Accounting Policies(1) Expenditures reported on the Schedule are reported on the accrual basis of accounting. This method is consistent with the preparation of the Corporations financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Corporation has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.(2) The Organization did not receive any non-cash awards during the fiscal year. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate.

Finding Details

Finding 2022-001 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917 and 21NU2RGH001917C6 Material Weakness/ Material Noncompliance Reporting Condition: During our testing of reporting, we noted that no formal review process was in place to independently review the FFR SF-425 (grant numbers 21NU2RGH001917 and 21NU2RGH001917C6 filed October 18, 2022) prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of the FFR SF-425 prior to report submission. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed FFR SF-425 report. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the FFR SF-425 report filing to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-001 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917 and 21NU2RGH001917C6 Material Weakness/ Material Noncompliance Reporting Condition: During our testing of reporting, we noted that no formal review process was in place to independently review the FFR SF-425 (grant numbers 21NU2RGH001917 and 21NU2RGH001917C6 filed October 18, 2022) prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of the FFR SF-425 prior to report submission. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed FFR SF-425 report. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the FFR SF-425 report filing to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-001 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917 and 21NU2RGH001917C6 Material Weakness/ Material Noncompliance Reporting Condition: During our testing of reporting, we noted that no formal review process was in place to independently review the FFR SF-425 (grant numbers 21NU2RGH001917 and 21NU2RGH001917C6 filed October 18, 2022) prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of the FFR SF-425 prior to report submission. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed FFR SF-425 report. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the FFR SF-425 report filing to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-001 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917 and 21NU2RGH001917C6 Material Weakness/ Material Noncompliance Reporting Condition: During our testing of reporting, we noted that no formal review process was in place to independently review the FFR SF-425 (grant numbers 21NU2RGH001917 and 21NU2RGH001917C6 filed October 18, 2022) prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of the FFR SF-425 prior to report submission. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed FFR SF-425 report. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the FFR SF-425 report filing to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan