2023 – 005 - Significant Deficiency in Internal Control Over Compliance: Allowable Costs and Activities
Recommendation:
1. Implement a Formal Expenditure Review and Approval Policy – Establish a policy requiring that all expenditures charged to grants be reviewed and approved by an appropriate...
2023 – 005 - Significant Deficiency in Internal Control Over Compliance: Allowable Costs and Activities
Recommendation:
1. Implement a Formal Expenditure Review and Approval Policy – Establish a policy requiring that all expenditures charged to grants be reviewed and approved by an appropriate individual before being recorded in the system.
2. Require Documentation of Review and Approval – Ensure that invoices, payroll allocations, and other cost support documents include a signature, initials, or system-generated approval to confirm review.
3. Utilize System-Based Controls – If possible, configure the financial system to require electronic approval for all grant-related expenditures before costs are recorded.
Management View: Management partially agrees with the finding. While we acknowledge that documentation of expenditure approval was not always retrievable, we believe the expenditures reviewed were all appropriate. Finding 2023-006 refers to the auditors’ assessment of expenditure review and approval processes that occurred in Calendar Year 2023. During Calendar Year 2023, Prism relied on email routing of expenditures for review and approval. As of this writing, Prism Health North Texas’ expenditure review and approval processes already meet or exceed the recommendations above.
Action Taken:
1. Expenditure Review – All expenditures charged to grants are reviewed and approved by two qualified individuals.
2. Documentation of Review and Approval –
a. Such review and approval for non-payroll expenditures occur in and are documented in the SAP Concur software before the costs are recorded in the accounting system (Abila).
b. Such review and approval for payroll-related expenditures occur via and are documented via a combination of methods, also before they are recorded in Abila.
i. Employees report their time, including how much time was devoted to grant activities, in the ExponentHR payroll system, and their supervisors approve both the time and the allocation in that system.
ii. Programmatic measures that also support grant billing (“units”) are calculated from activity documented in the athenaOne electronic health record (EHR).
iii. Payroll allocation is calculated by one person, based on the ExponentHR documentation and the units, then reviewed and imported into Abila by a second person. The unposted transactions are reviewed again before posting.
3. Utilize System-Based Controls – In place as above.
Anticipated Completion Date: The recommendations are already in place.
Responsible Contact Person(s):
• Name: General Laffitte
• Title: Vice President of Finance and Accounting
• Phone: 214-623-6896
• Address: 3900 Junius St. Ste. 300, Dallas, Texas 75246
• Name: Jana Voege
• Title: Chief Financial Officer
Address: 3900 Junius St. Ste. 300, Dallas, Texas 75246 Corrective Action Plan
Date: 4/28/2025
Cognizant or Oversight Agency for Audit
Prism Health North Texas respectfully submits the following corrective action plan for the year ended FY2023.
Name and address of independent public accounting firm:
Armanino LLP
15950 Dallas Pkwy #600, Dallas, TX 75248
(972) 661 - 1843
Audit Period:
The consolidated financial statements of AIDS Arms, Inc. were audited for the period of calendar year 2022 and 2023.
The findings from the year ended December 31, 2023, schedule of findings and questioned costs are discussed below. The Findings are numbered consistently with the numbers assigned in the schedule.