U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Cash Management Significant Deficiency in Internal Control over Compliance Criteria The OMB Compliance Supplement requires that non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition During our testing of reimbursement requests, there was no documentation available for the review and approval procedures performed. Cause The Organization did not have an adequate internal control policy to require the documentation of the reimbursement requests? review and approval. Effect Inaccurate reimbursement requests may be prepared, which could lead to amounts received in error. Questioned Costs None. Context/Sampling There was a total of seven reimbursement requests prepared for the year ended June 30, 2022. Of these, three were selected for testing. Two of the three did not contain documentation of the request being reviewed or approved. Repeat Finding from Yes. Prior Year(s) Recommendation We recommend the Organization enhance internal control policies to require documentation of the review and approval procedures performed in the preparation and review of reimbursement requests. Views of Responsible Management agrees with the finding. Individuals
U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Significant Deficiency in Internal Control over Compliance Criteria The OMB Compliance Supplement requires that non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition During our testing, there was no documentation of review and approval of employee timecards for a portion of the sample selected. Cause The Organization did not have an adequate internal control policy to ensure review and approval of employee timecards was documented. Effect The lack of adequate policies governing employee timecards increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs None. Context/Sampling A nonstatistical sample of 60 expenditures submitted for reimbursement were selected for testing. Of these 60, 3 did not show evidence of proper review and approval prior to payment. Repeat Finding from No. Prior Year(s) Recommendation We recommend that the Organization enhance internal control policies to ensure all employee timecards are reviewed and approved prior to payment to ensure that all payments are necessary and correct. Views of Responsible Management agrees with the finding. Individuals
U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Procurement and Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. Condition The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. Cause There is a lack of controls over the written procurement, suspension and debarment policy. Effect Failure to maintain a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations may result in disallowed costs. Questioned Costs None. Context/Sampling EB reviewed the procurement, suspension and debarment policy. Repeat Finding from No. Prior Year(s) Recommendation We recommend that management implement a written review procurement, suspension and debarment policy Federal, State, local, and tribal laws and regulations. We also recommend that management review this policy regularly to confirm that it meets the requirements. Views of Responsible Management agrees with the finding. Individuals
U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Cash Management Significant Deficiency in Internal Control over Compliance Criteria The OMB Compliance Supplement requires that non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition During our testing of reimbursement requests, there was no documentation available for the review and approval procedures performed. Cause The Organization did not have an adequate internal control policy to require the documentation of the reimbursement requests? review and approval. Effect Inaccurate reimbursement requests may be prepared, which could lead to amounts received in error. Questioned Costs None. Context/Sampling There was a total of seven reimbursement requests prepared for the year ended June 30, 2022. Of these, three were selected for testing. Two of the three did not contain documentation of the request being reviewed or approved. Repeat Finding from Yes. Prior Year(s) Recommendation We recommend the Organization enhance internal control policies to require documentation of the review and approval procedures performed in the preparation and review of reimbursement requests. Views of Responsible Management agrees with the finding. Individuals
U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Significant Deficiency in Internal Control over Compliance Criteria The OMB Compliance Supplement requires that non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition During our testing, there was no documentation of review and approval of employee timecards for a portion of the sample selected. Cause The Organization did not have an adequate internal control policy to ensure review and approval of employee timecards was documented. Effect The lack of adequate policies governing employee timecards increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs None. Context/Sampling A nonstatistical sample of 60 expenditures submitted for reimbursement were selected for testing. Of these 60, 3 did not show evidence of proper review and approval prior to payment. Repeat Finding from No. Prior Year(s) Recommendation We recommend that the Organization enhance internal control policies to ensure all employee timecards are reviewed and approved prior to payment to ensure that all payments are necessary and correct. Views of Responsible Management agrees with the finding. Individuals
U.S. Department of Health and Human Services Federal Financial Assistance Listing/CFDA Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services - 6H79SM083306-01M002 Procurement and Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. Condition The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. Cause There is a lack of controls over the written procurement, suspension and debarment policy. Effect Failure to maintain a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations may result in disallowed costs. Questioned Costs None. Context/Sampling EB reviewed the procurement, suspension and debarment policy. Repeat Finding from No. Prior Year(s) Recommendation We recommend that management implement a written review procurement, suspension and debarment policy Federal, State, local, and tribal laws and regulations. We also recommend that management review this policy regularly to confirm that it meets the requirements. Views of Responsible Management agrees with the finding. Individuals