Finding Text
Identification of the Federal Program:Federal Grantor: U.S. Department of Health and Human ServicesAssistance Listing No.: 93.011 ? National Organizations of State and Local OfficialsPass-Through Entity: Indiana State Department of HealthPass-Through Award Numbers: G32HS42634C6, U3SHS45317C6Award Years: G32HS42634C6: 07/31/2021-5/31/2023: U3SHS45317C6: 11/1/2021-7/31/2023Criteria or Specific Requirement (including statutory, regulatory or other citation):Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?Per Award Number 1 G32HS42634-01-00 and 1 U3SHS45317-01-00, Terms and Condition Section, page 3, subsection 5, ?As the grantee institution, you have the primary responsibility for developing and adhering to your organizational participant incentive policy and maintaining appropriate documentation for each participant gift card. Lastly, it is also the responsibility of the grant recipient to report all grant related costs and it is the responsibility of the sub-recipient to track and report these costs to you as the grant recipient?.Per the Corporation?s policy, section 12, ?During scheduled / clinic gift care pick up, CHW collects the following information to ensure the gift card is exchanged to the prequalified client who had received prior education: Vaccine Card (ensure 2nd or booster shot is documented), form of ID with the client?s name on it to match with vaccine card and internal spreadsheet, and internal spreadsheet for final confirmation of communication and exchange.?Condition:The Corporation screens applicants for eligibility to receive gift cards for participating in vaccine access programs. Once the applicant has met the guidelines of the program, a gift card is provided by the Corporation to the eligible participant. The Corporation expended the full balance of gift cards purchased during the fiscal year 2022 rather than the amount disbursed to eligible participants.Cause:The Corporation did not have internal controls that required the Corporation to only submit expenses for the gift cards disbursed to applicants.Effect or potential effect:The Corporation overstated program expenditures related to gift cards. Gift cards purchased were expensed on the schedule of expenditures of federal awards rather than the gift cards that have been distributed to eligible participants.Questioned Costs:$25,208Context:Gift card expenditure reported in the schedule of expenditures of federal awards for the year ended December 31, 2022, was $167,913. Total gift cards distributed to eligible participants was $142,705.Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 93.011 totaled $2,719,482 for the year ended December 31, 2022.Identification as a repeat finding, if applicable:No.Recommendation:The Corporation should revise its current internal controls to only record program expense for gift cards provided to eligible participants.Views of responsible officials:Management agrees with the finding. G32HS42634C6 and U3SHS45317C6 ended on May 31, 2023 and July 31, 2023, respectively, and therefore the remediation of the internal controls related to these programs is no longer applicable. However, if future programs are awarded, the Corporation will track the total gift cards purchased as a prepaid expense and expense the gift cards at the time they are distributed to eligible participants.