Finding Text
Federal Agency: United States Department of Treasury ALN: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: 1/1/2023 to 6/30/2025 Pass-Through Grantor Pass-Through Award Number Illinois Department of Human Services FCSDX06443, FCSDX06444, FCSDX06445 Federal Agency: United States Department of Health and Human Services Assistance Listing Federal Program Name Pass-Through Grantor Pass-Through Award Number 93.889 National Bioterrorism Hospital Preparedness Program Illinois Health and Hospital Association 197137 Illinois Department of Public Health 47280007L; 47280009L; 57280007M; and 57280009M 93.958 Block Grants for Community Mental Health Services Illinois Department of Human Services 45CCB03507 and 45CDB04209 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).” Section 200.430(g)(1)(vi) of the Uniform Guidance states that the standards for documentation of personnel expense must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity”. Condition: Management did not complete effort certifications for individuals working on multiple federal programs during the year. Cause: Management did not have sufficiently designed internal controls to ensure that effort certifications were completed for individuals working on multiple federal programs. Effect or potential effect: Unallowable payroll costs may be charged to the federal program. Questioned costs: None. Context: For Coronavirus State and Local Fiscal Recovery Funds, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service, Advocate Aurora Health did not have employees complete effort certifications when they were working on multiple federal programs. The total expenditures reported on the Schedule for Coronavirus State and Local Fiscal Recovery Funds, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service are $1,460,320, $952,593, and $926,262, respectively, for the year ended December 31, 2024. Payroll costs for Coronavirus State and Local Fiscal Recovery Fund, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service totaled $1,150,365, $94,265, and $752,385, respectively, representing 79%, 10%, and 81%, respectively of the total expenditures. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Organization should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the federal program. Views of responsible officials: Management agrees with the finding and will implement standardized procedures to ensure effort certifications are completed accurately and on time for all program staff.