Finding 2023-002 (L. Reporting)
Identification of the federal program:
Federal Agency: United States Department of Housing and Urban Development
Assistance Listing No.: 14.241 – Housing Opportunities for Persons with AIDS (HOPWA)
Pass-through Entities and Award Periods: Indiana Housing and Community Development Authority (IHCDA) – July 1, 2022 through June 30, 2023 and July 1, 2023 through June 30, 2024 and City of Indianapolis – April 1, 2022 through March 31, 2023 and April 1, 2024 through March 31, 2024
Criteria or specific requirement (Including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).”
Under the grant agreements, HOPWA grantees are required to submit performance reporting, specifically a HUD-40-110-D, HOPWA Consolidated Annual Performance and Evaluation Report (CAPER), no later than 90 days after the close of the program or operating year, as required per 24 CFR section 574.520.
Condition: The CAPER submission submitted by Indiana University Health, Inc. and Subsidiaries for the IHCDA grant for the period July 1, 2022 through June 30, 2023, incorrectly excluded $3,600 in funds expended on eligible activities (specifically, support services). For both the HOPWA CAPER submissions, the documentation retained did not support the extent of the review procedures performed prior to the CAPER submissions.
Cause: Indiana University Health, Inc. and Subsidiaries’ internal control over the CAPER reporting process was not operating effectively during the year ended December 31, 2023.
Effect or potential effect: Incorrect CAPER submissions were filed with HUD as a result of the control not operating effectively.
Questioned costs: None.
Context: Indiana University Health, Inc. and Subsidiaries submitted two CAPER reports during the year ended December 31, 2023. EY tested both CAPER reports for testing of internal controls over compliance and compliance for HOPWA reporting. The CAPER submission for the IHCDA grant for the period July 1, 2022 through June 30, 2023, incorrectly excluded $3,600 in funds expended on eligible activities. The documentation retained for both reports filed did not support the extent of the review procedures performed prior to the CAPER submissions.
Total federal expenditures for Assistance Listing No. 14.241 totaled $1,201,378 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable: This is not a repeat finding.
Recommendation: Indiana University Health, Inc. and Subsidiaries should ensure the completed CAPER and underlying support are sufficiently reviewed to identify discrepancies and documentation of those review procedures are maintained prior to submitting the CAPER.
Views of responsible officials: Indiana University Health, Inc. and Subsidiaries believes it appropriately designed procedures and internal controls over the HOPWA reporting requirements. Indiana University Health, Inc. and Subsidiaries agrees that the CAPER submission for the IHCDA grant for the period of July 1, 2022 through June 30, 2023, contained incomplete and inaccurate information. Indiana University Health, Inc. has revisited the internal control over HOPWA performance reporting