Finding Text
Finding No.: 2019-014
Federal Agency: U.S. Department of Health and Human Services
CFDA Program: 93.268 Immunization Cooperative Agreements
Award Numbers: 6NH231P000736-05-01 and 5NH231P000786-05-00
Area: Period of Performance
Questioned Costs: $80,809
Criteria:
In accordance with 45 CFR §75.309, 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 U.S. Department of Health and Human Services (HHS) awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Funds available to pay allowable costs during the period of performance include both federal funds awarded and carryover balances. In addition, a non-Federal entity must liquidate all obligations incurred under the award not later than 90 days after the end of the funding period. This deadline may be extended with prior written approval from the HHS awarding agency.
Condition:
Of nineteen expenditures tested, aggregating $88,887 of a total population of $778,897, the following deficiencies were noted:
1. For ten (or 53%), no supporting documents were provided to substantiate that the expenditures were incurred within the period of performance.
Finding No.: 2019-014, continued
Federal Agency: U.S. Department of Health and Human Services
CFDA Program: 93.268 Immunization Cooperative Agreements
Award Numbers: 6NH231P000736-05-01 and 5NH231P000786-05-00
Area: Period of Performance
Questioned Costs: $80,809
Condition, continued:
2. For eight (or 42%), cancelled checks or other form of payment were not provided; accordingly, CHCC was not able to substantiate that expenditures were liquidated within the grant award’s liquidation period.
3. For one (or 5%), liquidation occurred more than ninety days after the period of performance end date.
Of eight subsequent expenditures tested, aggregating $19,730 of a total population of $19,744, the following deficiencies were noted:
4. For seven (or 88%), supporting documents were not provided. Accordingly, CHCC was not able to substantiate that the expenditures were incurred/obligated within the period of performance end date of 06/30/19 and were liquidated within the liquidation period end date of 09/30/19.
Finding No.: 2019-014, continued
Federal Agency: U.S. Department of Health and Human Services
CFDA Program: 93.268 Immunization Cooperative Agreements
Award Numbers: 6NH231P000736-05-01 and 5NH231P000786-05-00
Area: Period of Performance
Questioned Costs: $80,809
Condition, continued:
5. For one (or 13%), the expenditure was liquidated after the liquidation period end date of 09/30/19.
Cause:
CHCC did not enforce recordkeeping and monitoring controls over compliance with applicable period of performance requirements.
Finding No.: 2019-014, continued
Federal Agency: U.S. Department of Health and Human Services
CFDA Program: 93.268 Immunization Cooperative Agreements
Award Numbers: 6NH231P000736-05-01 and 5NH231P000786-05-00
Area: Period of Performance
Questioned Costs: $80,809
Effect:
CHCC is in noncompliance with applicable period of performance requirements and questioned costs of $80,809 result.
Recommendation:
The responsible personnel should review funding period dates prior to charging expenditures to a federal award. They should also ensure that purchase order, contracts, checks or evidence that the check cleared are properly filed for support. Furthermore, the responsible personnel should monitor check payments to ensure that liquidations occur in a timely manner. If extensions are necessary, grantor approval should be sought.
Views of Responsible Officials:
CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 3 to 5, and states agreement with Conditions 1 and 2; however, disagrees with the questioned costs.
Auditor Response:
Conditions 1 and 2 - Questioned costs are warranted given transactions tested were not supported by adequate documentations.
Condition 3 - Condition pertains to liquidation requirement and not obligation requirement.
Finding No.: 2019-014, continued
Federal Agency: U.S. Department of Health and Human Services
CFDA Program: 93.268 Immunization Cooperative Agreements
Award Numbers: 6NH231P000736-05-01 and 5NH231P000786-05-00
Area: Period of Performance
Questioned Costs: $80,809
Auditor Response, continued:
Conditions 4 and 5 - Documentations provided by the Director of Grants and Fiscal Integrity on 09/27/24 do not pertain to transactions tested.
In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.