Finding 1094324 (2023-003)

Finding 2023-003 Significant deficiency in internal control over compliance with the level of effort requirements applicable to the major program. Federal Agency: Department of Health and Human Services (HHS) Pass-Through: State of Washington Department of Health (DOH) Program Title: HIV Prevention Activities Health Department Assistance Listing Number: 93.940 Award Number: CBO27200; CBO28119 Award Period: July 01, 2022 through August 31, 2023 and July 01, 2023 through December 31, 2023 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Sections 200.301 and 200.329, require that a non-federal must measure and report on performance progress when the federal awards includes specific program goals, indicators, targets, baseline data, data collection, or expected outcomes with an expected timeline for accomplishment. The non-federal entity is responsible for oversight of the operations of the federal award supported activities and must monitor its activities under Federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Condition/Context for Evaluation The federal awards tested require that for each 1.0 FTE dedicated to this service category, 100 annual PrEP/prevention navigation clients should be served and registered in Provide. The contractor will enter all client-level data in Provide. During our testing, we noted that the Organization was not monitoring this metric. Cause The Organization’s management was not aware of their responsibility to monitor against the level of effort requirement stated in the grant agreement. Effect or Potential Effect Without proper monitoring, the Organization may not meet the requirement specified in the federal award. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Organization implement internal control processes to ensure compliance with the program’s level of effort requirements. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.