Finding 1099832 (2023-004)

Material Weakness Repeat Finding
Requirement
ABCG
Questioned Costs
-
Year
2023
Accepted
2025-02-17
Audit: 342657
Organization: Hope Community Services, Inc. (OK)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: Hope lacks adequate documentation to support payroll allocations and compliance with grant requirements, risking noncompliance with federal regulations.
  • Impacted Requirements: This affects allowable costs, cash management, and level of effort as outlined in the grant contract.
  • Recommended Follow-Up: Implement controls for reviewing and approving payroll allocations and expenditures, ensuring they align with grant requirements and are substantiated by proper documentation.

Finding Text

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022 – 8/30/2023 Allowable Activities or Unallowed, Allowable Costs/Cost Principles, Cash Management, and Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.403) as it relates to federal grants: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity; d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part; f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; g) Be adequately documented; h) Cost must be incurred during the approved budget period. Per the grant policy manual for Department of Health and Human Services: Non-federal entities must minimize the time elapsing between any advance payment under this award and the disbursement of the funds for direct program costs. 2 CFR Part 200, OMB Compliance Supplement, defines Level of Effort as follows: Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non-federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non-federal funding of services. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support the drawdown from grant funding or that the level of effort requirements, as outlined in the grant contract, was achieved. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective federal grant programs. Or, if such documentation did exist, it could not be provided as audit evidence. As a result, certain expenditures were claimed as program expenditures, but could not be substantiated for purposes of allowable costs or level of effort. Much of the issue can be attributed to employee turnover. Effect: Hope is at risk for noncompliance with allowable activities and allowable costs, as well as cash management and level of effort requirements. Questioned costs: None reported. Context: A nonstatistical sampling of 70 out of over 1,500 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles. Allocation support could not be provided for any of the 60 items selected. Two of 7 drawdowns of grant funds were selected for testing of Cash Management which where nonstatistical. Support could not be provided for the 2 items selected. 2 of 2 employees were tested with respect to level of effort requirements as outlined in the program contract, but supporting information could not be provided. Repeat Finding From Prior Year: Yes Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Controls should be put in place to ensure that direct expenditures of program funds are reviewed and approved by program management and are consistent with the grant reimbursements for those expenditures. Such reconciliations can be done monthly, quarterly, or annually, at Hope’s discretion. Controls should also ensure that program expenditures are made prior to requesting reimbursement of funds and are allowable in accordance with the federal program requirements. Views of Responsible Officials: We agree with the finding.

Categories

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 523389 2023-003
    Material Weakness Repeat
  • 523390 2023-004
    Material Weakness Repeat
  • 523391 2023-005
    Material Weakness
  • 523392 2023-005
    Material Weakness
  • 523393 2023-005
    Material Weakness
  • 1099831 2023-003
    Material Weakness Repeat
  • 1099833 2023-005
    Material Weakness
  • 1099834 2023-005
    Material Weakness
  • 1099835 2023-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $1.38M
14.238 Shelter Plus Care Program $200,500
93.958 Block Grants for Community Mental Health Services $84,522
64.024 Va Homeless Providers Grant and Per Diem Program $74,727
93.788 Opioid Str $54,855
93.150 Projects for Assistance in Transition From Homelessness (path) $49,424
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $45,754
93.959 Block Grants for Prevention and Treatment of Substance Abuse $43,740
14.267 Continuum of Care Program $38,195
16.593 Residential Substance Abuse Treatment for State Prisoners $28,912
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $27,650
16.585 Treatment Court Discretionary Grant Program $2,190