Finding Text
Federal Agency: United States Department of Health and Human Services ALN: 93.788 Opioid STR Pass-Through Grantor: Illinois Department of Human Services Pass-Through Award Number: 43CCC03512 Award Period: 7/1/2023 to 6/30/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Exhibit B of the grant agreement dated June 12, 2024 between the State of Illinois, Department of Human Services and Advocate Health & Hospitals, patients who are residents of the State of Illinois and have indicated diagnosis of Opioid Use Disorder (OUD) are eligible to receive services. Condition: Management did not accurately document and retain evidence of the state of residency for participants in the federal program. Cause: Management did not have sufficiently designed internal controls to ensure that participants in the program were eligible to receive services through the program. Effect or potential effect: Ineligible participants may participate and receive benefits from the federal program. Questioned costs: None. Context: We tested a sample of 40 participants in the federal program for the period January 1, 2024 through December 31, 2024 and identified 8 participants where eligibility could not be redetermined or established. For seven of the participants, documentation was not retained to evidence the participants’ state of residence and for one participant they were listed as a resident of another state. The total Opioid STR expenditures reported on the Schedule are $1,105,537 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Organization should review its policies and procedures for determining and retaining evidence of participants’ eligibility and implement more robust internal controls to ensure proof of residency is confirmed and retained for participants in the federal program. Views of responsible officials: Management agrees with this finding and will develop a more robust process to verify participant eligibility. This process will include detailed steps and documentation, supported by a standardized eligibility checklist to guide staff in confirming and accurately recording participant eligibility.