Finding 1147808 (2023-005)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2025-07-15

AI Summary

  • Core Issue: The organization lacks a documented approval process for expenditures charged to federal grants, which raises compliance risks.
  • Impacted Requirements: This finding violates federal regulations requiring effective internal controls and documentation for allowable costs under 2 CFR §200.
  • Recommended Follow-Up: Implement a formal approval policy, ensure documentation of reviews, and utilize system-based controls for all grant-related expenditures.

Finding Text

Finding number: 2023-005 Significant Deficiency in Internal Control Over Compliance: Allowable Costs and Activities Federal Program #1 HIV Emergency Relief Project Grants: CFDA Number 93.914 Federal Program #2 HIV Care Formula Grants: CFDA Number 93.917 Federal Program #3 HIV Prevention Activities: CFDA Number: 93.941 Name of federal agency: U.S. Department of Health and Human Services (HHS) Name of pass-through entity: Multiple Repeat finding: No AIDS Arms, Inc. dba Prism Health North Texas and Subsidiary Schedule of Findings and Questioned Costs For the Year Ended December 31, 2023 SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Criteria: Under 2 CFR §200.303, recipients of federal funds must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms of grant agreements. 2 CFR §200.403 specifies that costs charged to federal programs must be allowable, necessary, reasonable, and allocable to the respective award. Additionally, 2 CFR §200.302 requires financial management systems to provide effective control and accountability over federal funds, including documented approval of expenditures. A best practice for grant compliance is to implement a documented approval process for expenditures charged to federal programs, ensuring that all costs are reviewed and supported by adequate documentation before reimbursement requests are submitted. Condition: The Organization did not have readily-available documented evidence of review and approval for expenditures charged to federal grants during the fiscal year. Specifically:  The financial system did not capture or document approval of expenditures before they were charged to federal programs.  No formalized system existed to retain evidence of grant-related expenditure reviews.  While the prior Chief Financial Officer (CFO) manually reviewed each invoice, there was no indication of approval on the supporting documentation, making it impossible to verify that an appropriate review occurred before costs were charged to the grants. Cause: The issue arose due to the Organization's reliance on a manual review process conducted by the previous CFO, without requiring a formal approval signature or electronic system control to document review. This lack of a structured approval process resulted in insufficient evidence to support compliance with federal allowable cost requirements. AIDS Arms, Inc. dba Prism Health North Texas and Subsidiary Schedule of Findings and Questioned Costs For the Year Ended December 31, 2023 SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Possible effect: Without a documented approval process, the Organization cannot demonstrate that expenditures charged to the grants were properly reviewed for allowability, reasonableness, and allocability in accordance with federal regulations. This increases the risk that:  Unallowable or misclassified expenditures could be charged to the grants without detection.  Noncompliance with federal grant requirements could result in questioned costs or additional oversight from funding agencies.  Financial statement and grant reporting inaccuracies may occur if expenditures are not properly reviewed and approved. Although no specific unallowable costs were identified during the audit, the lack of documented review represents a significant deficiency in internal control over compliance. Questioned cost: None identified at this time. Recommendation: We recommend that the Organization strengthen its internal controls over grant expenditures by implementing the following measures: 1. Implement a Formal Expenditure Review and Approval Policy – Establish a policy requiring that all expenditures charged to grants be reviewed and approved by an appropriate individual before being recorded in the system. 2. Require Documentation of Review and Approval – Ensure that invoices, payroll allocations, and other cost support documents include a signature, initials, or system-generated approval to confirm review. 3. Utilize System-Based Controls – If possible, configure the financial system to require electronic approval for all grant-related expenditures before costs are recorded. AIDS Arms, Inc. dba Prism Health North Texas and Subsidiary Schedule of Findings and Questioned Costs For the Year Ended December 31, 2023 SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Views of responsible officials: Management partially agrees with the finding. While we acknowledge that documentation of expenditure approval was not always retrievable, we believe the expenditures reviewed were all appropriate. Finding 2023-005 refers to the auditors' assessment of expenditure review and approval processes that occurred in Calendar Year 2023. During Calendar Year 2023, Prism relied on email routing of expenditures for review and approval. As of this writing, Prism Health North Texas' expenditure review and approval processes already meet or exceed the recommendations above. Action Taken: Expenditure Review – All expenditures charged to grants are reviewed and approved by two qualified individuals. Documentation of Review and Approval – Such review and approval for non-payroll expenditures occur in and are documented in the SAP Concur software before the costs are recorded in the accounting system (Abila). Such review and approval for payroll-related expenditures occur via and are documented via a combination of methods, also before they are recorded in Abila. Employees report their time, including how much time was devoted to grant activities, in the ExponentHR payroll system, and their supervisors approve both the time and the allocation in that system. Programmatic measures that also support grant billing ("units") are calculated from activity documented in the athenaOne electronic health record (EHR). Payroll allocation is calculated by one person, based on the ExponentHR documentation and the units, then reviewed and imported into Abila by a second person. The unposted transactions are reviewed again before posting. Utilize System-Based Controls – In place as above. _________________________________________________________

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 571359 2023-004
    Material Weakness
  • 571360 2023-005
    Significant Deficiency
  • 571361 2023-006
    Significant Deficiency
  • 571362 2023-004
    Material Weakness
  • 571363 2023-005
    Significant Deficiency
  • 571364 2023-006
    Significant Deficiency
  • 571365 2023-004
    Material Weakness
  • 571366 2023-005
    Significant Deficiency
  • 571367 2023-006
    Significant Deficiency
  • 571368 2023-004
    Material Weakness
  • 571369 2023-005
    Significant Deficiency
  • 571370 2023-006
    Significant Deficiency
  • 571371 2023-004
    Material Weakness
  • 571372 2023-005
    Significant Deficiency
  • 571373 2023-006
    Significant Deficiency
  • 571374 2023-004
    Material Weakness
  • 571375 2023-005
    Significant Deficiency
  • 571376 2023-006
    Significant Deficiency
  • 571377 2023-004
    Material Weakness
  • 571378 2023-005
    Significant Deficiency
  • 571379 2023-006
    Significant Deficiency
  • 571380 2023-004
    Material Weakness
  • 571381 2023-005
    Significant Deficiency
  • 571382 2023-006
    Significant Deficiency
  • 571383 2023-004
    Material Weakness
  • 571384 2023-005
    Significant Deficiency
  • 571385 2023-006
    Significant Deficiency
  • 1147801 2023-004
    Material Weakness
  • 1147802 2023-005
    Significant Deficiency
  • 1147803 2023-006
    Significant Deficiency
  • 1147804 2023-004
    Material Weakness
  • 1147805 2023-005
    Significant Deficiency
  • 1147806 2023-006
    Significant Deficiency
  • 1147807 2023-004
    Material Weakness
  • 1147809 2023-006
    Significant Deficiency
  • 1147810 2023-004
    Material Weakness
  • 1147811 2023-005
    Significant Deficiency
  • 1147812 2023-006
    Significant Deficiency
  • 1147813 2023-004
    Material Weakness
  • 1147814 2023-005
    Significant Deficiency
  • 1147815 2023-006
    Significant Deficiency
  • 1147816 2023-004
    Material Weakness
  • 1147817 2023-005
    Significant Deficiency
  • 1147818 2023-006
    Significant Deficiency
  • 1147819 2023-004
    Material Weakness
  • 1147820 2023-005
    Significant Deficiency
  • 1147821 2023-006
    Significant Deficiency
  • 1147822 2023-004
    Material Weakness
  • 1147823 2023-005
    Significant Deficiency
  • 1147824 2023-006
    Significant Deficiency
  • 1147825 2023-004
    Material Weakness
  • 1147826 2023-005
    Significant Deficiency
  • 1147827 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.941 Hiv Demonstration, Research, Public and Professional Education Projects $887,872
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges $720,011
93.940 Hiv Prevention Activities Health Department Based $638,227
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $470,256
93.939 Hiv Prevention Activities Non-Governmental Organization Based $420,071
93.994 Maternal and Child Health Services Block Grant to the States $391,322
93.914 Hiv Emergency Relief Project Grants $263,463
93.917 Hiv Care Formula Grants $243,462
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $150,000
93.145 Hiv-Related Training and Technical Assistance $106,520
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $66,691
93.855 Allergy and Infectious Diseases Research $24,615
93.837 Cardiovascular Diseases Research $10,356
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $3,788