Finding 1147722 (2023-005)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2025-07-14

AI Summary

  • Core Issue: Unallowable sales tax was charged to federal programs due to inadequate internal controls, impacting compliance with federal cost principles.
  • Impacted Requirements: Violations of 2 CFR Part 200 regarding allowable costs and the need for effective fund management.
  • Recommended Follow-Up: Improve invoice review processes, track vendor credits for proper reallocations, and train staff on cost allowability to prevent future issues.

Finding Text

Federal Programs Affected: • 11.302 – Economic Development Administration (EDA) • 93.041 – Preventive Health and Health Services – Ombudsman • 93.043 – Prevention and Public Health – Evidence-Based Health Promotion (Title III-D) • 93.071 – Medicare Enrollment Assistance (MIPPA) • 93.324 – State Primary Care Offices (HICAP) • 93.499 – ACA – LIHWAP Cluster • 93.791 – Money Follows the Person – ADRC • 93.917 – HIV Care Formula Grants – Ryan White Service Delivery • 97.067 – Homeland Security Grant Program – SHSP Compliance Requirement: Allowable Costs/Cost Principles (2 CFR Part 200, Subpart E) Type of Finding: Compliance and Internal Control Deficiency Condition: During our review of administrative expenditures, we identified a utility payment to NRG Business that included sales tax, which is unallowable under federal cost principles for tax-exempt entities. Specifically, the utility invoice dated June 30, 2023, in the amount of $713.43 included $51.47 in sales tax. Although the vendor later issued a credit for the sales tax amount, the original charge—including the unallowable portion—was allocated to various federal grants through the administrative cost pool. It is not clear whether the vendor credit was properly reallocated to reverse the original federal charges. The table below summarizes the impacted programs and amounts: Federal Program ALN Check No. Amount Charged Economic Development Administration 11.302 #70335 $66.99 Preventive Health & Health Services – Ombudsman 93.041 #70076 $56.16 Evidence-Based Health – Title III-D 93.043 #70335 $66.99 Medicare Enrollment Assistance – MIPPA 93.071 #70583 $75.50 State Primary Care Offices – HICAP 93.324 #71046 $80.00 ACA – LIHWAP Cluster 93.499 #69835 $43.14 Money Follows the Person – ADRC 93.791 #70335 $66.99 HIV Care Formula Grants – Ryan White 93.917 #70460 $35.63 Homeland Security Grant Program – SHSP 97.067 #69835 $43.14 Criteria: In accordance with 2 CFR §200.403 and §200.405, costs charged to federal awards must be necessary, reasonable, allocable, and allowable under the cost principles. As a tax-exempt entity, sales taxes paid in error are considered unallowable unless excluded from reimbursement or properly credited. Additionally, per §200.302(b)(2), recipients must maintain effective control over and accountability for all funds and ensure proper allocation of costs. Cause: STDC’s internal controls did not identify the inclusion of sales tax in the vendor invoice prior to payment. Furthermore, no mechanism was in place to ensure that vendor credits—once received—were retroactively applied to reverse the original allocations made to federal grants. Effect: Although the vendor issued a credit for the unallowable sales tax, the original amount was temporarily charged to multiple federal programs. The lack of documented reallocation creates a risk that federal programs may have absorbed unallowable costs or that cost allocations remain inaccurate. Recommendation: We recommend that STDC: • Strengthen internal controls to ensure that invoices are reviewed for unallowable costs (such as sales tax) prior to payment and allocation; • Establish procedures to track vendor credits and ensure that corresponding cost reallocations are applied to the correct funding sources; • Enhance documentation and reconciliation processes to demonstrate that post-payment adjustments are handled properly; • Train fiscal and grant staff on exempt status implications and cost allowability under Uniform Guidance. Questioned Costs: None (vendor credit issued); however, audit adjustments or reallocations may be necessary to ensure grant charges are corrected.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 571263 2023-005
    Significant Deficiency
  • 571264 2023-002
    Significant Deficiency
  • 571265 2023-003
    Significant Deficiency
  • 571266 2023-003
    Significant Deficiency
  • 571267 2023-004
    Significant Deficiency
  • 571268 2023-004
    Significant Deficiency
  • 571269 2023-004
    Significant Deficiency
  • 571270 2023-005
    Significant Deficiency
  • 571271 2023-005
    Significant Deficiency
  • 571272 2023-005
    Significant Deficiency
  • 571273 2023-005
    Significant Deficiency
  • 571274 2023-005
    Significant Deficiency
  • 571275 2023-005
    Significant Deficiency
  • 571276 2023-005
    Significant Deficiency
  • 571277 2023-005
    Significant Deficiency
  • 571278 2023-005
    Significant Deficiency
  • 571279 2023-005
    Significant Deficiency
  • 571280 2023-005
    Significant Deficiency
  • 571281 2023-005
    Significant Deficiency
  • 1147705 2023-005
    Significant Deficiency
  • 1147706 2023-002
    Significant Deficiency
  • 1147707 2023-003
    Significant Deficiency
  • 1147708 2023-003
    Significant Deficiency
  • 1147709 2023-004
    Significant Deficiency
  • 1147710 2023-004
    Significant Deficiency
  • 1147711 2023-004
    Significant Deficiency
  • 1147712 2023-005
    Significant Deficiency
  • 1147713 2023-005
    Significant Deficiency
  • 1147714 2023-005
    Significant Deficiency
  • 1147715 2023-005
    Significant Deficiency
  • 1147716 2023-005
    Significant Deficiency
  • 1147717 2023-005
    Significant Deficiency
  • 1147718 2023-005
    Significant Deficiency
  • 1147719 2023-005
    Significant Deficiency
  • 1147720 2023-005
    Significant Deficiency
  • 1147721 2023-005
    Significant Deficiency
  • 1147723 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.917 Hiv Care Formula Grants $3.96M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.42M
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $1.04M
93.053 Nutrition Services Incentive Program $325,834
93.568 Low-Income Home Energy Assistance $289,161
93.052 National Family Caregiver Support, Title Iii, Part E $252,381
14.241 Housing Opportunities for Persons with Aids $167,026
93.499 Low Income Household Water Assistance Program $115,424
93.569 Community Services Block Grant $79,616
11.302 Economic Development Support for Planning Organizations $77,580
97.067 Homeland Security Grant Program $40,000
93.324 State Health Insurance Assistance Program $37,548
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $35,775
93.791 Money Follows the Person Rebalancing Demonstration $31,025
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $20,043
16.034 Coronavirus Emergency Supplemental Funding Program $14,800
93.071 Medicare Enrollment Assistance Program $12,900
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $12,791
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $4,431
93.072 Lifespan Respite Care Program $2,512
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $1,393