Finding 1159877 (2024-002)

Mental and Behavioral Health Education and Training Grants Assistance Listing No. 93.732 U.S. Department of Health and Human Services Program Year 2024 Criteria or Specific Requirement – Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) Condition – The District should only charge and be reimbursed by the grant for allowable expenditures based on the grant agreement. Questioned Costs – $4,579 – calculated as expenditures tested related to unallowable meal costs. Context – During the year, the District held a conference which was primarily funded by the grant. Included in conference expenditures charged to the grant were meal catering costs which are not allowable based on grant requirements. Effect – The District charged unallowable costs to the grant. Cause – The District included meal cost as grant expenditures which were incurred through a conference primarily funded by the grant. Identification as a repeat finding – N/A Recommendation – Expenses directly charged to a federal award should be reviewed to ensure costs are allowable. Views of Responsible Officials and Planned Corrective Actions – Responsible Official: Aaron Davis, VP & Chief Experience Officer Planned Corrective Actions: We were using verbal guidance around meals, specifically page 84 of HHS Grants Policy Statement which states as follows under Consumer/ Provider Board Participation: “Allowable in accordance with applicable program regulations. When not specifically authorized by program regulations, only the following costs are allowable with OPDIV prior approval: The reasonable costs of necessary meals furnished by the recipient to consumer or provider participants during scheduled meetings if not reimbursed to participants as per diem or otherwise.” The conference in question was held outside some participants shift time so light refreshments were provided. However, in order to ensure compliance with the Notice of Award Terms and Conditions Grant Specific Term #5, the University Medical Center will not submit unallowable meal costs and provide refresher for existing grant Program Managers to ensure they understand the terms and conditions to avoid unallowable costs and discuss the terms and conditions with the HRSA Grants Management Specialist and Project Officer if questions arise.