Finding 1157630 (2024-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369843
Organization: Wabanaki Health and Wellness (ME)
Auditor: Wipfli LLP

AI Summary

  • Core Issue: There is a significant deficiency in internal controls related to compliance with major federal programs due to inadequate segregation of duties.
  • Impacted Requirements: Access to critical accounting functions is not properly restricted, increasing the risk of errors or fraud.
  • Recommended Follow-Up: Management should limit user access based on roles and implement review procedures by individuals without access to sensitive financial data.

Finding Text

Finding Number 2024-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated consolidated financial statements. This is a repeat finding from the December 31, 2023 audit, finding number 2023-003, the December 31, 2022 audit, finding number 2022-003 and the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Corrective Action Plan

2024-003- Significant Deficiency - Segregation of Duties WPHW understands this finding and continues to work to sufficiently segregate duties. In October 2024, we implemented more rigorous segregation of duties procedures that have been fully implemented in FY25. In addition, we have restructured our accounting team to ensure proper segregation of duties. WPHW has implemented the following process to ensure the separation of duties: 1) Accounting Specialists will have access to the accounting software and will not have any access to the bank accounts for entry of information. 2) Accounting Manager and Accounting Specialists will have read-only access to the bank accounts and full access to the accounting software to verify and review day-to-day transactions. 3) The Director of Accounting will have full access to the bank and review only access to the accounting software to do the proper review process. 4) Tasks can be handed off between staff within each level, but to ensure appropriate separation of duties, task cannot cross levels We believe that this issue has been fully resolved in FY25.

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1157608 2024-001
    Material Weakness Repeat
  • 1157609 2024-002
    Material Weakness Repeat
  • 1157610 2024-003
    Material Weakness Repeat
  • 1157611 2024-007
    Material Weakness Repeat
  • 1157612 2024-001
    Material Weakness Repeat
  • 1157613 2024-002
    Material Weakness Repeat
  • 1157614 2024-003
    Material Weakness Repeat
  • 1157615 2024-007
    Material Weakness Repeat
  • 1157616 2024-001
    Material Weakness Repeat
  • 1157617 2024-002
    Material Weakness Repeat
  • 1157618 2024-003
    Material Weakness Repeat
  • 1157619 2024-007
    Material Weakness Repeat
  • 1157620 2024-001
    Material Weakness Repeat
  • 1157621 2024-002
    Material Weakness Repeat
  • 1157622 2024-003
    Material Weakness Repeat
  • 1157623 2024-007
    Material Weakness Repeat
  • 1157624 2024-001
    Material Weakness Repeat
  • 1157625 2024-002
    Material Weakness Repeat
  • 1157626 2024-003
    Material Weakness Repeat
  • 1157627 2024-007
    Material Weakness Repeat
  • 1157628 2024-001
    Material Weakness Repeat
  • 1157629 2024-002
    Material Weakness Repeat
  • 1157631 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.772 Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement $2.80M
93.859 Biomedical Research and Research Training $1.32M
93.872 Tribal Maternal, Infant, and Early Childhood Home Visiting $561,578
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $392,563
93.493 Community Project Funding/congressionally Directed Spending - Construction $351,763
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $350,989
10.766 Community Facilities Loans and Grants $306,675
93.959 Block Grants for Prevention and Treatment of Substance Abuse $146,930
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $123,146
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $100,102
93.762 A Comprehensive Approach to Good Health and Wellness in Indian County Ð Financed Solely by Prevention and Public Health $94,056
93.958 Block Grants for Community Mental Health Services $65,164
93.268 Immunization Cooperative Agreements $64,282
15.032 Indian Economic Development $53,890
93.387 National and State Tobacco Control Program (b) $46,283
93.270 Adult Viral Hepatitis Prevention and Control $43,061
93.940 Hiv Prevention Activities_health Department Based $41,013
21.023 Emergency Rental Assistance Program $39,478
15.144 Indian Child Welfare Act_title II Grants $26,489
93.558 Temporary Assistance for Needy Families $26,068
93.136 Injury Prevention and Control Research and State and Community Based Programs $12,304
10.568 Emergency Food Assistance Program (administrative Costs) $11,673
93.647 Social Services Research and Demonstration $10,524
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $10,254
10.225 Community Food Projects $7,337
93.788 Opioid Str $6,408
21.027 Coronavirus State and Local Fiscal Recovery Funds $1,291