Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).
Criteria or specific requirement: According to ? 2 CFR 200.303 Internal controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to HRSA's Provider Relief Lost Revenues Guide, grants would be excluded from the Patient Care Lost Revenue calculation. Condition: The Organization included grant revenue recognized within the Provider Relief Fund (PRF) Period 3 Lost Revenues calculation and Period 3 report. The Organization was able to recalculate their Period 3 Lost Revenues utilizing Option 1, 2019 actuals to 2020 actuals, less grant revenues recognized, which resulted in Lost Revenues of $1,329,975. Total PRF Period 3 funds received was $1,000,765. The Organization did not utilize any of the PRF Period 3 funds to reimburse expenditures. Questioned costs: None. Context: The Organization's PRF Period 3 report currently includes grant revenues within the 2019-2022 Actuals tables within the other section. Cause: Management Oversight. Effect: Future Lost Revenues available to be reimbursed by future PRF funds is currently less as shown on the PRF Period 3 report as the PRF Period 3 report includes grant revenues. Repeat Finding: No. Recommendation: We recommend the Organization provide HRSA with their revised Lost Revenues calculation as the current eligible lost revenues reported on the PRF Period 3 report appears to be understated. Views of responsible officials: Management concurs with the finding. Due to the complexity and lack of clarity on PRF reporting, the period 3 lost revenues calculation was understated. The HRSA portal is closed so Mental Health Partners is not able to provide an updated and current lost revenue report for Period 3. However, the Mental Health Partners has not received and does not anticipate receiving any additional PRF funds, so no future impact is expected or additional corrective action needed. Should additional funds be received, the CFO and Controller will adjust future reporting as needed.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).
Criteria or specific requirement: According to ? 2 CFR 200.303 Internal controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to HRSA's Provider Relief Lost Revenues Guide, grants would be excluded from the Patient Care Lost Revenue calculation. Condition: The Organization included grant revenue recognized within the Provider Relief Fund (PRF) Period 3 Lost Revenues calculation and Period 3 report. The Organization was able to recalculate their Period 3 Lost Revenues utilizing Option 1, 2019 actuals to 2020 actuals, less grant revenues recognized, which resulted in Lost Revenues of $1,329,975. Total PRF Period 3 funds received was $1,000,765. The Organization did not utilize any of the PRF Period 3 funds to reimburse expenditures. Questioned costs: None. Context: The Organization's PRF Period 3 report currently includes grant revenues within the 2019-2022 Actuals tables within the other section. Cause: Management Oversight. Effect: Future Lost Revenues available to be reimbursed by future PRF funds is currently less as shown on the PRF Period 3 report as the PRF Period 3 report includes grant revenues. Repeat Finding: No. Recommendation: We recommend the Organization provide HRSA with their revised Lost Revenues calculation as the current eligible lost revenues reported on the PRF Period 3 report appears to be understated. Views of responsible officials: Management concurs with the finding. Due to the complexity and lack of clarity on PRF reporting, the period 3 lost revenues calculation was understated. The HRSA portal is closed so Mental Health Partners is not able to provide an updated and current lost revenue report for Period 3. However, the Mental Health Partners has not received and does not anticipate receiving any additional PRF funds, so no future impact is expected or additional corrective action needed. Should additional funds be received, the CFO and Controller will adjust future reporting as needed.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.302(b)(6), Requirements for Financial Management, the financial management system of each non-Federal entity must provide written procedures to implement the requirements of ? 2 CFR 200.305 Federal Payments. Condition: The Organization's Financial and Control Policy does not include any procedures that address the requirements of ? 2 CFR 200.305. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.302(b)(6). Cause: The Organization lacks written procedures that address the Federal Payments requirements. Effect: Noncompliance with federal regulations. Repeat Finding: Yes: 2021-004 Recommendation: We recommend the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Views of responsible officials: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305.
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.
Criteria or specific requirement: According to ? 2 CFR 200.332 Requirements for Pass-through Entities, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Questioned costs: None. Context: We noted the Organization is not in compliance with the requirements defined within 2 CFR ?200.332(b). Cause: The Organization lacks established internal controls and procedures that ensure a risk assessment is performed on all Subrecipients. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Appropriate subrecipient monitoring may not be determined as there are no risk assessments being performed. Repeat Finding: Yes: 2021-003 Recommendation: We recommend the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Views of responsible officials: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b).