2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families, Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health ...
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families, Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual departments typically charge Federal awards for indirect costs through an indirect cost rate. A separate indirect cost rate proposal for each operating department is usually necessary to claim indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each operating department of the State, local government, or Indian Tribe carrying out Federal awards; and (2) the costs of central governmental services distributed through the central service cost allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1) of forty (40) transactions was not a department cost that should have been included in the pooled cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558, and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County Department without SSA’s review/approval for allowable activities. The other County department inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not follow their procedures to ensure allowable costs were properly reported as a cost that can be specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major programs tested were as follows:
•
Medicaid Cluster (93.558) - $16,329
•
Foster Care Title IV-E (93.658) - $17,009
•
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs (93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct benefit to the department’s various federally funded programs.
Management Response and Corrective Action:
1. Person Responsible: Jackqueline Ly, Financial Services Fiscal Administrator
2. Corrective Action Plan:
SSA will work with other county agency’s financial team to ensure all transactions affecting SSA's ledger are reviewed and posted correctly. Conduct a monthly reconciliation of cost pool to verify compliance with allowable cost principles and provide more regular trainings for staff involved in cost allocations and expense tracking/reporting.
3. Anticipated Implementation date: April 2025