Finding Text
2023-005 2023-005 Accuracy over Federal Reporting Requirements (Repeat Finding 2022-004)
Program Name: State Opioid Response Federal Assistance
Listing No.: 93.788
Federal Agency: Department of Health and Human Services
Federal Award Identification: Unknown
Pass-Through Entity Number: Unknown
Applicable Pass-Through Entity: Ohio Department of Mental Health and Addiction Services and
Cuyahoga County, Ohio
Type of Finding: Material Weakness
Compliance Requirement: Reporting
Criteria: Under Section 200.303 of the Uniform Guidance, a non-federal entity must maintain effective internal controls to ensure compliance with federal statutes, regulations, and award terms. Point of Freedom needs to establish and document policies and procedures to meet control objectives outlined in 2 CFR Section
200.1, particularly ensuring accurate recording and accounting of transactions for reliable financial statements and federal reports.
Condition: Our federal reports testing revealed inaccuracies in the reports, with supporting documentation failing to corroborate the submitted information. Additionally, management has not provided adequate support to verify the accuracy of these reports.
Cause of Condition: The Organization's lack of developed policies and procedures for compliance has led to the identified deficiencies in federal reports.
Effect: Inadequate controls in this compliance area pose a significant risk that the Organization may fail to meet federal award reporting requirements.
Questioned Cost: Not Quantifiable
Context: We selected three months' worth of monthly reports for ADAMHS and one closeout report for OHMAS.
Recommendation: We recommend that management develop and implement policies and procedures that address compliance requirements. Additionally, provide comprehensive training to employees on these policies and ensure consistent monitoring to maintain accuracy and timeliness in federal reporting. We also suggest a review process.
Views of Responsible Officials: POF's initial and current exposure a few months later to Single Audit compliance requirements have sharpened its focus on the need to purposefully identify and maintain corroborating evidence regarding its timely submission and acceptance by each of the respective funding sources. While POF believes that all these reporting requirements were timely met and accepted by all funding sources, it did not consistently maintain either the report itself, or the related documentation such as copies of the emails sent or the associated read-receipts as evidence of these reports. Effective July 1, POF routinely and consistently accumulated and organized these documents as well as ancillary evidence of their transmission to, receipt by, and acknowledgement of acceptance by the federal agency.
POF will be more diligent in its transmissions to funders. POF noted that the 2022 Closeout Report was inexplicably re-submitted instead of the correct 2023 Closeout Report. This is unacceptable, and POF will add a second set of reviews by a second person to improve quality control in this area. As necessary, POF will seek professional education and advice in implementing policies, practices, and procedures in addition to those already described herein.