Finding 1080208 (2023-002)

U.S. Department of Health and Human Services Certified Community Behavioral Health Clinics Assistance Listing #93.696 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: 5H79SM086922-02 2023-002 U.S. Department of Health and Human Services Certified Community Behavioral Health Clinics Assistance Listing #93.696 Matching, Level of Effort, Earmarking Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: 5H79SM086922-02 Criteria – A complete system of internal control contemplates an adequate system for tracking level of effort of designated personnel as prescribed in Notice of Award from U.S. Department of Health and Human Services. OMB require official written policy outlining responsibilities for determining required amounts or limits for level of effort, calculations for level of effort (including in-kind), and methods of accounting for and documentation of level of effort. Condition – Excelsior did not timely submit notice to granting agency of change in evaluator, as required by award. Cause – Due to cost constraints and the limited size of staff, Excelsior did not follow their policies or controls for communicating change in evaluator to granting agency. Effect – Excelsior could be out of compliance with the terms of the award. Questioned Costs – None reported Context/Sampling – All job functions/employees named in the award tested Repeat Finding from Prior Year – No Recommendation – We recommend Excelsior implement revised policies and documentation for segregated responsibilities for level of effort requirements. Views of Responsible Officials – Management agrees with the finding.