Finding Text
Finding 2021-001 Preparation of the Schedule Expenditures of Federal Awards – Material
Weakness in Internal Control Over Compliance
Program: U.S. Department of Health and Human Services
HRSA COVID-19 Uninsured Program
ALN 93.461
Award year: 2021
Criteria: The Uniform Guidance (2 CFR 200) Section 200.510 requires an auditee to
“prepare a schedule of expenditures of Federal awards (SEFA) for the period
covered by the auditee’s financial statements [that]….at a minimum shall…list
individual Federal programs by Federal agency…[and] provide total Federal
awards expended for each individual Federal program and the Assistance
Listing Number (ALN) number or other identifying number when the ALN
information is not available.” In accordance with Uniform Guidance,
Confluence Health (the Health System) is required to maintain a structure of
internal control to ensure compliance with applicable reporting requirements.
Condition/Cause: The Health System did not have sufficient controls to ensure the SEFA
included all expenditures that qualified as an expenditure of a federal award
during the period.
Effect: The SEFA was revised to include $2,036,330 of expenditures related to ALN
#93.461, HRSA COVID-19 Uninsured Program, which resulted in an
additional major program and the reissuance of the 2021 reporting
package. Additionally, it was determined that the Health System had not
properly reported approximately $1.0 million in expenditures related to this
same program in its prior year SEFA.
Questioned Costs: Not applicable.
Context: Factors contributing to the condition included the high volume of activity
related to new COVID-19 programs and the lack of understanding that the
related payments represented grant expenditures from a Federal source that
were required to be reported on the SEFA.
Repeat Finding: Not applicable.
Recommendation: We recommend the Health System develop and implement a review process
through the year to ensure compliance with SEFA reporting requirements as
outlined in the Uniform Guidance.
Views of Responsible
Officials:
Processes will be put in place to compile the SEFA, reconcile to support, and
perform a related review prior to audit. This will allow all grants from a Federal
source to be identified and tracked, ensuring completeness.