Finding Text
2023-002 – Cash Management
Federal agency: U.S. Department of Health and Human Services
Federal program title: Health Centers Cluster
Assistance Listing Number: 93.224/93.527
Pass-Through Agency: n/a
Pass-Through Number(s): n/a
Award Period: 9/1/23-8/31/25; 4/1/21-3/31/23; 6/1/19-5/31/23; 6/1/23-5/31/26; 12/1/22-5/31/23
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific
Requirement: § 200.305(b)(3) indicates reimbursement of costs previously occurred is an acceptable method for requesting payment of Federal funds. However, the Organization is responsible for determining that the entity paid for the costs for which reimbursement is being requested, prior to the date of the reimbursement request.
Condition: The Organization could not provide documentation to support that the draw down request was prepared by someone independent of the person who reviewed the request.
Questioned Costs: None.
Context: For six of six drawdowns selected for testing, CLA was able to obtain documentation of approval prior to draw down, but there was no documentation to support segregation of duties in the draw down process.
Cause: Management turnover.
Effect: Lack of segregation of duties could result in inaccurate amounts being drawn down.
Repeat Finding: No.
Recommendation: CLA recommends that the Organization maintain documentation of the individual preparing the draw down request, along documentation of an independent review being performed prior to the drawdown. This can be in the form of sign off, email, checklist, etc.
Views of Responsible
Officials: There is no disagreement with the audit finding.