FAC Explorer

Finding 1078306 (2023-003)

Significant Deficiency
Requirement
H
Questioned Costs
$1
Year
2023
Accepted
2024-10-07
Audit: 323960
Organization: Elizabeth Glaser Pediatric Aids Foundation (DC)
Auditor: Bdo USA LLP

AI Summary

  • Core Issue: $74,584 in costs were recorded after the end of the award's performance period, violating federal compliance requirements.
  • Impacted Requirements: Non-Federal entities must only charge allowable costs incurred during the specified period and liquidate obligations within 120 days post-period unless authorized otherwise.
  • Recommended Follow-Up: Revise internal procedures to better detect out-of-period expenditures and consider closing the project in the accounting system to manage post-period costs effectively.

Finding Text

2023-003 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Identification of the Major Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Award Number: NU2GGH002010 Award Period: September 30, 2021 to March 31, 2023 Criteria or Specific Requirement: In accordance with §200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by §200.344(b). When used in connection with a non-Federal entity’s utilization of funds under a Federal award, “obligations” means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in §200.71. Condition: During our period of performance completeness testing, BDO identified $74,584 of costs that were recorded after the period of performance. This was identified as part of our sampling analytics. Cause: The Foundation management has procedures in place to review expenditures to determine the appropriate period of performance; however, those procedures were not performed to a level of detail at the international office to identify expenses that were incurred outside the period of performance. Effect: The lack of adherence to the established internal control procedures around the period of performance of the award resulted in noncompliance and questioned costs that need to be returned to the Centers for Disease Control. Continued noncompliance with federal statutes,regulations, and the provisions of the award agreements could ultimately result in additional disallowed costs for the major program. Questioned Costs: $74,584 of known costs. Context: BDO’s testing of the period of performance compliance requirement was performed by examining whether the expenses selected as part of our testing of allowable costs and allowable activities were incurred within the proper period of performance of the award. Our subsequent testing of additional detailed expenditures identified no further samples that were recorded incorrectly. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance in order to prevent the charging of costs outside of the period of performance of the award. Furthermore, we believe an option would be to close the project within the accounting system, and create a separate project to accumulate any costs incurred after the end of the period of performance. The costs incurred subsequent to the end of the period of performance should go through the review and approval of individuals at the Foundation’s Headquarters. Views of Responsible Officials: The Foundation management agrees with the finding and recommendations set forth within and will provide training to appropriate staff responsible for monitoring expenses on the program. Refer to management’s corrective action plan for additional information.

Categories

Questioned Costs Subrecipient Monitoring Period of Performance

Other Findings in this Audit

  • 501841 2023-002
    Significant Deficiency
  • 501842 2023-002
    Significant Deficiency
  • 501843 2023-002
    Significant Deficiency
  • 501844 2023-002
    Significant Deficiency
  • 501845 2023-002
    Significant Deficiency
  • 501846 2023-002
    Significant Deficiency
  • 501847 2023-002
    Significant Deficiency
  • 501848 2023-002
    Significant Deficiency
  • 501849 2023-002
    Significant Deficiency
  • 501850 2023-002
    Significant Deficiency
  • 501851 2023-002
    Significant Deficiency
  • 501852 2023-002
    Significant Deficiency
  • 501853 2023-002
    Significant Deficiency
  • 501854 2023-002
    Significant Deficiency
  • 501855 2023-002
    Significant Deficiency
  • 501856 2023-002
    Significant Deficiency
  • 501857 2023-002
    Significant Deficiency
  • 501858 2023-002
    Significant Deficiency
  • 501859 2023-002
    Significant Deficiency
  • 501860 2023-002
    Significant Deficiency
  • 501861 2023-002
    Significant Deficiency
  • 501862 2023-002
    Significant Deficiency
  • 501863 2023-002
    Significant Deficiency
  • 501864 2023-003
    Significant Deficiency
  • 1078283 2023-002
    Significant Deficiency
  • 1078284 2023-002
    Significant Deficiency
  • 1078285 2023-002
    Significant Deficiency
  • 1078286 2023-002
    Significant Deficiency
  • 1078287 2023-002
    Significant Deficiency
  • 1078288 2023-002
    Significant Deficiency
  • 1078289 2023-002
    Significant Deficiency
  • 1078290 2023-002
    Significant Deficiency
  • 1078291 2023-002
    Significant Deficiency
  • 1078292 2023-002
    Significant Deficiency
  • 1078293 2023-002
    Significant Deficiency
  • 1078294 2023-002
    Significant Deficiency
  • 1078295 2023-002
    Significant Deficiency
  • 1078296 2023-002
    Significant Deficiency
  • 1078297 2023-002
    Significant Deficiency
  • 1078298 2023-002
    Significant Deficiency
  • 1078299 2023-002
    Significant Deficiency
  • 1078300 2023-002
    Significant Deficiency
  • 1078301 2023-002
    Significant Deficiency
  • 1078302 2023-002
    Significant Deficiency
  • 1078303 2023-002
    Significant Deficiency
  • 1078304 2023-002
    Significant Deficiency
  • 1078305 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.067 Project Alcancar - Advancing Sustainable Implementation of Comprehensive Hiv/tb Services for Epidemic Control in Mozambique $23.14M
98.001 Usaid/tanzania’s Client-Centered Health Program Hiv and Tuberculosis Northern $19.65M
93.067 Project Inili - Implementation of Comprehensive Programs for the Prevention, Care, and Treatment of Hiv/aids in the Republic of Cote D'ivoire Under Pepfar $12.17M
93.067 Develop, Implement, and Sustain High Quality Comprehensive Hiv Cascade Activities for Children, Adolescents, and Adults in Facility and Community Based Settings in Cameroon Under the President`s Emergency Plan for Aids Relief $11.36M
93.067 Score95 - Sustaining Hiv Epidemic Control Through Efficient Case Finding and Quality Care and Treatment Services in Malawi Under Pepfar $10.78M
98.001 Usaid Lesotho - Push $10.72M
93.067 Egpaf Accelerating Lesotho's Progress to Epidemic Control Through Health System Strengthening and Delivery of Comprehensive Hiv/tb Care, Treatment and Prevention Services Under Pepfar $9.88M
93.067 Improving Quality of Care and Health Impact Through Innovative Systems and Technologies in Malawi Under the President's Emergency Plan for Aids Relief $9.49M
98.001 Usaid/southern Africa's Attain & Sustain 95-95-95, Prevent New Infections and Reach All Populations for Epidemic Control (aspire) $6.66M
98.001 Usaid Ihap - Drc $4.61M
98.001 Usaid/uganda Health Activity $4.54M
93.067 Achieving Hiv Epidemic Control Through Scaling Up Quality Testing, Care and Treatment in Malawi Under Pepfar $4.37M
12.350 Drc Dhapp-Fardc Elikya Project $4.16M
93.067 Vukisha 95 - Kenya - Py2 $2.68M
98.001 Usaid Uganda (rhites) $1.82M
93.067 Covid - Targeted Programmatic Support Across Countries Under the Global Fund to Fight Hiv/aids, Tuberculosis and Malaria and Under the President's Emergency Plan for Aids Relief $1.65M
93.067 Dhibiti Py1 $1.46M
93.067 Achieving and Maintaining Epidemic Control Through Comprehensive Hiv/aids Prevention, Care and Treatment Services in the Kinshasa Region of the Democratic Republic of Congo - Py2 $1.18M
93.067 Targeted Programmatic Support Across Countries Under the Global Fund to Fight Hiv/aids, Tuberculosis and Malaria and Under the President's Emergency Plan for Aids Relief $968,157
93.067 Covid - Egpaf Accelerating Lesotho's Progress to Epidemic Control Through Health System Strengthening and Delivery of Comprehensive Hiv/tb Care, Treatment and Prevention Services Under Pepfar $627,566
98.001 Covid - Usaid Lesotho - Push $454,668
98.001 Usaid/tanzania’s Client-Centered Health Program Covid - Hiv and Tuberculosis Northern $448,531
98.001 Supporting, Mobilizing, and Accelerating Research for Tuberculosis Elimination (smrt4tb) $426,952
93.067 Dhibiti Py2 $375,337
98.001 Covid - Usaid/southern Africa's Attain & Sustain 95-95-95, Prevent New Infections and Reach All Populations for Epidemic Control (aspire) $298,686
93.067 Covid - Develop, Implement, and Sustain High Quality Comprehensive Hiv Cascade Activities for Children, Adolescents, and Adults in Facility and Community Based Settings in Cameroon Under the President`s Emergency Plan for Aids Relief $263,543
98.001 Covid - Usaid Ihap - Drc $222,942
12.350 Covid - Department of Defense (dod) Hiv/aids Prevention Program $191,176
93.067 Covid - Project Alcancar - Advancing Sustainable Implementation of Comprehensive Hiv/tb Services for Epidemic Control in Mozambique $142,010
93.067 Achieving and Maintaining Epidemic Control Through Comprehensive Hiv/aids Prevention, Care and Treatment Services in the Kinshasa Region of the Democratic Republic of Congo - Py3 $62,145
98.001 Usaid Tanzania - Chsd $22,917
93.067 Covid - Improving Quality of Care and Health Impact Through Innovative Systems and Technologies in Malawi Under the President's Emergency Plan for Aids Relief $15,328
93.067 Vukisha 95 $11,205
93.067 Implementation of Programs for the Prevention, Care and Treatment of Hiv/aids in the Republic of Côte D'ivoire Under Pepfar $5,599
93.067 Strengthening the Capacity of Faith-Based Organizations (fbos) and Faith-Based Health Systems to Sustain the Role of Fbos in A Coordinated Response to Hiv/aids $43
93.067 Supporting the Implementation and Expansion of High Quality, Sustainable and Comprehensive Hiv Prevention, Care and Treatment Programs in the Western Region and Turkana County of the Republic of Kenya Under Pepfar $-9,250
93.067 Achieving and Maintaining Epidemic Control Through Comprehensive Hiv/aids Prevention, Care and Treatment Services in the Kinshasa Region of the Democratic Republic of Congo - 2021 $-17,472
12.350 Department of Defense (dod) Hiv/aids Prevention Program $-189,151