Finding 1157077 (2024-005)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369390
Organization: Unity Health Care, Inc. (MD)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The Corporation lacks proper documentation and internal controls for managing indirect costs related to Federal awards, violating 2 CFR 200.303(a) and Appendix IV requirements.
  • Impacted Requirements: Indirect costs charged do not consistently conform to allowability provisions in 2 CFR Part 200, Subpart E, leading to potential compliance risks.
  • Recommended Follow-Up: Develop and implement formal policies and internal controls to ensure compliance with indirect cost allowability requirements and address repeat findings.

Finding Text

Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the Federal award that provides assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, 2 CFR Appendix IV to Part 200 Section B.2(b) requires that both the direct costs and the indirect costs must exclude capital expenditures and unallowable costs. Per Compliance Supplement, these indirect costs must conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Condition: During our testing of indirect costs, we noted that the Corporation charges the Federally approved rate of 28.7% on specific grant awards based on direct salaries and wages. However, the Corporation did not maintain ongoing supporting documentation of eligible indirect costs. Cause: The Corporation did not have formal process and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). Effect or Potential Effect: Additional efforts after year end were required to determine whether indirect costs charged to Federal awards conform to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Allowable costs incurred by the Corporation exceeded the amount of approved grant funding, therefore no questioned costs are reported. Questioned costs: None Context: Additional efforts after year end were required by management in order to provide sufficient and appropriate evidence that the reported indirect costs conformed to the allowability of cost provisions in 2 CFR Part 200, Subpart E or award agreement. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2023-009 in the 2023 report. Recommendation: We recommend the Corporation develop and incorporate internal controls and policies to demonstrate adherence to the allowability requirements of indirect costs in accordance with 2 CFR Appendix IV to Part 200 Section B.2(b). View of Responsible Officials: Due to staff turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine an updated indirect cost rate. Also, the current indirect cost rate allocations is based on historical assumptions.

Corrective Action Plan

Management Response #2024-005: Due to staff turnover the Corporation did not have adequate personnel or infrastructure in place to monitor costs in order to calculate and determine an updated indirect cost rate. Also, the current indirect cost rate allocations is based on historical assumptions. Corrective Action Plan: The Finance Team will develop overall operational costs reports to calculate and support a new rate. The proposed rate will be submitted to HRSA for approval. This will allow us to ensure the calculation for indirect costs and documentation supporting the indirect cost pool conform to the current regulations. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1157059 2024-001
    Material Weakness Repeat
  • 1157060 2024-002
    Material Weakness Repeat
  • 1157061 2024-003
    Material Weakness Repeat
  • 1157062 2024-001
    Material Weakness Repeat
  • 1157063 2024-002
    Material Weakness Repeat
  • 1157064 2024-003
    Material Weakness Repeat
  • 1157065 2024-001
    Material Weakness Repeat
  • 1157066 2024-002
    Material Weakness Repeat
  • 1157067 2024-005
    Material Weakness Repeat
  • 1157068 2024-001
    Material Weakness Repeat
  • 1157069 2024-002
    Material Weakness Repeat
  • 1157070 2024-005
    Material Weakness Repeat
  • 1157071 2024-001
    Material Weakness Repeat
  • 1157072 2024-002
    Material Weakness Repeat
  • 1157073 2024-005
    Material Weakness Repeat
  • 1157074 2024-001
    Material Weakness Repeat
  • 1157075 2024-002
    Material Weakness Repeat
  • 1157076 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $7.41M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $5.37M
93.788 Opioid Str $1.47M
93.914 Hiv Emergency Relief Project Grants $1.24M
93.217 Family Planning Services $1.11M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $451,849
93.917 Hiv Care Formula Grants $395,938
93.247 Advanced Nursing Education Workforce Grant Program $343,619
93.855 Allergy and Infectious Diseases Research $330,035
93.994 Maternal and Child Health Services Block Grant to the States $287,682
93.837 Cardiovascular Diseases Research $259,513
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $118,679
93.884 Primary Care Training and Enhancement $99,465
93.527 Grants for New and Expanded Services Under the Health Center Program $72,274
93.526 Grants for Capital Development in Health Centers $62,276
93.426 The National Cardiovascular Health Program $57,990
93.107 Area Health Education Centers $53,711
93.242 Mental Health Research Grants $1,519