Finding 1062125 (2023-007)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-09-04

AI Summary

  • Core Issue: CBNHC improperly awarded premium pay to Board members who do not qualify as "essential workers" under the SLFRF Final Rule.
  • Impacted Requirements: Compliance with the SLFRF Final Rule regarding allowable costs for premium pay to essential workers.
  • Recommended Follow-Up: CBNHC should reassess the eligibility of Board members and consider recovering $10,416 in questioned costs if they do not meet the essential worker criteria.

Finding Text

2023-007 — Allowable Costs Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2022 – 9/30/2023 Criteria: CBNHC was awarded funding under its Master Contract and AFA under the State and Local Fiscal Recovery Funds (SLFRF). One allowable use of funds under the SLFRF Final Rule is for premium pay to essential workers. Premium pay is designed to compensate workers that, by virtue of their employment, were forced to take on additional burdens and make great personal sacrifices as a result of the COVID–19 pandemic. The SLFRF Final Rule defines eligible workers as ‘‘those workers needed to maintain continuity of operations of essential critical infrastructure sectors and additional sectors as each government may designate as critical to protect the health and wellbeing of residents”. Condition: In November 2022, all employees and Board members of CBNHC received premium pay based on months of service during fiscal year 2022. However, Board members do not appear to meet the definition of an “essential worker” as defined under the SLFRF Final Rule. Context: N/A Questioned Costs: $10,416. Cause: CBNHC Board of Directors approved premium pay to all employees, IPA/MOA contractor employees, and Board members regardless of whether each position was needed to maintain continuity of operations. Effect: CBNHC is not in compliance with the SLFRF Final Rule related to this funding under the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should evaluate the SLFRF Final Rule and determine whether Board members meet the definition of an “essential worker”. CBNHC should consider requesting reimbursement of these funds from Board members if it is determined that Board members do not meet the definition of an “essential worker” under the SLFRF Final Rule. Management’s Response: CBNHC acknowledges that its Board members did not meet the definition of an “essential worker” and therefore, is not in compliance with the SLFRF Final Rule related to the relief funding under the Indian Self-Determination program.

Categories

Questioned Costs Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 485678 2023-003
    - Repeat
  • 485679 2023-003
    - Repeat
  • 485680 2023-004
    Material Weakness Repeat
  • 485681 2023-005
    Significant Deficiency Repeat
  • 485682 2023-006
    Significant Deficiency
  • 485683 2023-007
    Significant Deficiency
  • 485684 2023-003
    - Repeat
  • 485685 2023-003
    - Repeat
  • 485686 2023-003
    - Repeat
  • 485687 2023-003
    - Repeat
  • 485688 2023-003
    - Repeat
  • 485689 2023-004
    Material Weakness Repeat
  • 485690 2023-005
    Significant Deficiency Repeat
  • 485691 2023-006
    Significant Deficiency
  • 485692 2023-007
    Significant Deficiency
  • 1062120 2023-003
    - Repeat
  • 1062121 2023-003
    - Repeat
  • 1062122 2023-004
    Material Weakness Repeat
  • 1062123 2023-005
    Significant Deficiency Repeat
  • 1062124 2023-006
    Significant Deficiency
  • 1062126 2023-003
    - Repeat
  • 1062127 2023-003
    - Repeat
  • 1062128 2023-003
    - Repeat
  • 1062129 2023-003
    - Repeat
  • 1062130 2023-003
    - Repeat
  • 1062131 2023-004
    Material Weakness Repeat
  • 1062132 2023-005
    Significant Deficiency Repeat
  • 1062133 2023-006
    Significant Deficiency
  • 1062134 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.441 Indian Self-Determination $528,472
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $249,062
93.495 Community Health Workers for Public Health Response and Resilient $24,629
93.788 Opioid Str $21,066
93.772 Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement $15,120
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $14,477