Finding 1138194 (2024-004)

Significant Deficiency
Requirement
BH
Questioned Costs
$1
Year
2024
Accepted
2025-05-29
Audit: 357417
Organization: Change Happens! (TX)

AI Summary

  • Core Issue: Significant deficiencies in compliance with allowable costs and period of performance across multiple federal programs.
  • Impacted Requirements: Errors in coding and charging costs led to unallowable expenses, violating Uniform Guidance cost principles.
  • Recommended Follow-Up: Reinforce adherence to policies for reviewing coding and maintaining payroll spreadsheets to prevent future errors.

Finding Text

Finding #2024-004 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-03-03, Contract year: 08/27/23 – 08/26/24, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Children’s Health Insurance Program, Assistance Listing #93.767, Contract #2Y2CMS331859-02-05, Contract year: 07/01/23 – 06/30/25. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPS, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPU, Contract year: 09/01/23 – 08/31/24. Criteria: Allowable costs and period of performance – The Uniform Guidance, Subpart E Cost Principles, establishes costs principles which must be followed for expenditures to be allowable and requires a system of internal controls sufficient to ensure that costs are properly charged to the appropriate general ledger object and class code. The Uniform Guidance §200.309 period of performance requires expenditures be incurred during the period of the federal grant award in order to be allowable. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost compliance – all major programs, In a sample of 59 non-payroll transactions tested for internal controls over compliance: One instance of annual advertising contract charged in full rather than establishing a prepaid expense for the eleven months after Civic Heart’s year-end of August 31, 2024. The applicable grant period is July 1, 2023 through June 30, 2025 and thus, only one month, or approximately $417, was outside the period of performance (AL #93.767 Children’s Health Insurance Program). One instance of $2,700 charged to wrong program. Allowable costs of the Navigator program were charged to Connecting Kids program due to coding to the wrong class code in the general ledger. (AL#93.767 Children’s Health Insurance Program (Connecting Kids). In a sample of 135 payroll transactions tested for internal controls over compliance: Four instances of errors in the amount of costs charged to class code due to a clerical error in the payroll allocation spreadsheet. (AL #93.959 Block Grants for Prevention and Treatment of Substance Abuse and AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based). Other non-compliance: AL #93.767 Children’s Health Insurance Program: In a sample of 40 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($417). AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 42 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($2,700). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based: In a sample of 40 payroll or vendor charges, two instances of non-compliance with allowable costs due to charge to the wrong program. Controls over period of performance – all major programs. In a sample of 56 vendor transactions and 4 pay periods with grant beginning or ending dates during the audit period, we found: 13 instances of charging vendor costs to the wrong grant period. One instance of charging payroll costs to the wrong grant period. Other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 14 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $3,120). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based. In a sample of 27 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $480). In a sample of four pay periods tested, we found one exception for charging costs to the wrong grant period (approximately $5,350). AL# 93.959 Block Grants for Prevention and Treatment of Substance Abuse. In a sample of 25 vendor charges tested, we found 5 exceptions for charging to the wrong grant period (approximately $660). Cause: Failure to follow Civic Heart’s policies and procedures related to review of coding for charges to the general ledger. Effect: Failure to follow established internal control policies and procedures resulted in errors and unallowable costs being charged to the grant. Questioned costs: $12,727. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance of payroll spreadsheets and reviews of coding for all transactions. View of responsible officials: Management agrees with the finding. See Corrective Action Plan.

Categories

Questioned Costs Allowable Costs / Cost Principles Period of Performance

Other Findings in this Audit

  • 561751 2024-003
    Material Weakness Repeat
  • 561752 2024-004
    Significant Deficiency
  • 561753 2024-005
    Significant Deficiency
  • 561754 2024-003
    Material Weakness Repeat
  • 561755 2024-004
    Significant Deficiency
  • 561756 2024-003
    Material Weakness Repeat
  • 561757 2024-004
    Significant Deficiency
  • 561758 2024-003
    Material Weakness Repeat
  • 561759 2024-004
    Significant Deficiency
  • 1138193 2024-003
    Material Weakness Repeat
  • 1138195 2024-005
    Significant Deficiency
  • 1138196 2024-003
    Material Weakness Repeat
  • 1138197 2024-004
    Significant Deficiency
  • 1138198 2024-003
    Material Weakness Repeat
  • 1138199 2024-004
    Significant Deficiency
  • 1138200 2024-003
    Material Weakness Repeat
  • 1138201 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges $1.78M
14.267 Continuum of Care Program $1.10M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $796,876
93.939 Hiv Prevention Activities Non-Governmental Organization Based $766,735
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $581,094
93.767 Children's Health Insurance Program $529,943
93.060 Sexual Risk Avoidance Education $483,375
16.830 Girls in the Juvenile Justice System $253,705
16.812 Second Chance Act Reentry Initiative $219,405
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $156,015
21.027 Coronavirus State and Local Fiscal Recovery Funds $114,306
93.558 Temporary Assistance for Needy Families $112,319
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $65,553
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $26,848
16.548 Delinquency Prevention Program $13,147