Finding Text
Material Weakness in Internal Control over Compliance
2024-004 Activities Allowed or Unallowed and Allowable Costs/Costs Principles
Program: Community Services Block Grant (CSBG) & Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)(HCH).
Federal Assistance Listing No: 93.569 and 93.224
County Recipient: Community Action Partnership of Natrona County
Federal Agency: Department of Health and Human Services
Grant year: 2023 and 2024
Federal Award Identification: Unknown
Applicable Pass-through Entity: Wyoming Department of Health (CSBG), Direct (HCH)
Criteria
Accounting practices of the non-Federal entity must provide for adequate documentation to support costs charged to the Federal award. Standards for accounting practices in Uniform Guidance 2 CFR part 200.400 state that the accounting practices of the recipient and subrecipient must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the Federal award.
Condition
CAP was missing a consistent system of internal control for accumulation of costs charged to the federal program. The detail of costs maintained in the accounting system charged to the grants differed from the amounts included in the reimbursement requests.
Cause
Due to an accounting system conversion, adjustments were made in the general ledger to the beginning account balances. This resulted in unreconcilable differences from the detail in the accounting system after adjustment to what was originally submitted for reimbursement. Additionally, CAP began utilizing a separate payroll provider that required an integration of the payroll register monthly to the general ledger. Mapping and coding errors existed during the initial integrations of the payroll register to the general ledger resulting in additional differences from the general ledger to the amounts submitted for reimbursement for wage and benefit expense allocated to the grants.
Effect or Potential Effect
CAP was unable to provide an accurate accumulation of costs for amounts charged to the grant.
Questioned Cost
93.224 - $9,274
93.569 - $28,355
Context
The comparison of the general ledger for grant costs to the total of the amounts submitted for reimbursement resulted in differences of $9,274 for the Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) grant, and $28,355 Community Services Block Grant.
Identification as a repeat finding
This is not a repeat finding
Recommendation
We recommend CAP review its policies and procedures related to the internal controls over accumulation of expenditures related to grants to ensure the detail agrees to amounts submitted for reimbursement.
Views of Responsible Officials
Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention.
See Corrective Action Plan