Finding 1160338 (2024-002)

Material Weakness Repeat Finding
Requirement
ABH
Questioned Costs
-
Year
2024
Accepted
2025-10-11

AI Summary

  • Core Issue: The Organization lacks proper documentation and review processes for payroll expenses related to federal grants, leading to a material weakness in internal controls.
  • Impacted Requirements: Non-compliance with federal regulations on Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance.
  • Recommended Follow-Up: Implement stricter internal controls, ensure proper documentation and approvals for payroll, and establish independent reviews of vouchers and reports.

Finding Text

Finding 2024-002 Material Weakness in Internal Control Over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Period of Performance and Reporting Assistance Listing Numbers 93.958 Block Grants for Community Mental Health Services 93.959 Block Grants for Prevention and Treatment Substance Abuse 93.696 Certified Community Behavioral Health Clinic (CCBHC) – Planning, Development, and Implementation Grants Federal Agency U.S. Department of Health and Human Services Passthrough Agency Illinois Department of Human Services Award Number/Year 2024 Criteria The Organization is responsible for keeping an accurate accounting of all federal expenditures and maintaining all of the required documentation and reports in accordance with applicable federal regulations. Condition For AL No. 93.958, Block Grants for Community Mental Health Services Program, a sample of twenty-nine (29) payroll expense and fringe benefits transactions were tested for Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance. For AL No. 93.959, Block Grants for Prevention and Treatment of Substance Abuse Program, a sample of thirty (30) payroll expense and fringe benefits transactions were tested for Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance. For AL No. 93.696, Certified Community Behavioral Health Clinic (CCBHC) – Planning, Development, and Implementation Grants Program, a sample of forty-four (44) payroll expense and fringe benefits transactions were tested for Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance. The Organization was not able to provide sufficient evidence of review and approval of employee salaries and wages charged to these grants. We did note that the payroll and fringe benefit expense transactions tested matched the appropriate vouchers for reimbursement and related supporting documentation of payroll expense and fringe benefits. It was also noted that one person prepared, reviewed and submitted all vouchers and reports which is an indication of improper segregation of duties. Cause The Organization did not follow its established policies and procedures regarding documentation of the time sheets or time studies supporting the allocation of salaries and fringe benefits for each employee charged to grants. Additionally, there was no support in each employee file regarding a merit increase provided in December 2023 for all employees. Effect The Organization is not in compliance with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance requirements of its grant agreements within its federally funded programs as prescribed by Uniform Guidance. Questioned Costs None noted. Repeat Finding Yes Recommendation We recommend that the Organization implement the following corrective actions: • Enforce its current specific internal control procedures to ensure compliance with applicable federal regulations. • Require that all personnel files have authorization and approval of current pay rates along with correspondence regarding to which grant an employee’s salary and fringe benefits should be expensed including any allocations if the employee worked on several grants. • Require that all vouchers and reports be prepared by one individual and independently reviewed and approved by a second individual prior to submission. There should be documentation of the review such as a sign-off or initials. • Require that all vouchers and reports be filed timely in accordance with the various grant agreements. • Require that correspondence be received from those agencies indicating that required reports per the written grant agreements are not necessary when applicable. • Ensure that the data collection form is filed the earlier of thirty (30) days after the report date or no later than nine (9) months after the fiscal year-end. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Corrective Action Plan

The Organization will implement the following corrective actions for the fiscal year ending June 30, 2024 to remediate the finding and address the cause of the finding. The Organization has hired staff with higher technical accounting skills than the previous staff. The following staff have been hired full-time or will be hired soon: Payroll and Benefits Specialist, Grant Accountant, Senior Staff Accountant, Accounts Payables and Receivables Specialist, and a Purchasing Specialist. • The Organization’s Human Resources has implemented quarterly audits on all new staff to verify each new staff member hired within the last year has a signed employee offer and appropriate backup support to support each employee’s annual salary. • The Organization has implemented a new accounting system – Sage Intacct. Additionally, we have implemented a grants project tracking module to better help with grants and contracts reporting and compliance. • The Organization has implemented a new payroll and human resources IT solution – UKG. All manual and onboarding processes have been implemented within the system for tracking and auditing purposes. • The Organization will implement an established month-end checklist for all monthly entries to be completed by assigned finance staff. We will ensure that all staff are trained adequately to handle any assigned task. All monthly entries are required to be reviewed and approved by the Chief Financial Officer prior to posting to the general ledger within our new Accounting Software. All appropriate backup documentation will be saved and stored within the accounting software. • All grant related year-end audit procedures has been transitioned to the Grant Accountant who has experience with audits, compliance, and reporting for City, State, and Federal grants. • The Organization has documented accounting policies and procedures to reflect the new month-end processes and provide training to staff on current and future policies. • The Organization will ensure that Finance personnel receive a minimum of twenty-five (25) hours of training annually of relevant accounting topics including updates to generally accepted accounting principles, generally accepted government accounting principles, nonprofit and governmental financial reporting, and other related accounting trainings. • The Organization will ensure that any personnel involved in financial reporting have the technical expertise to help with the preparation, review, and analysis of the financial statements and supplementary information. The target date for implementation is April 2025. The responsible party for the planned resources will be Raheel Shahzad, Chief Financial Officer (708) 288-7897. Our address is 340 E. 51st St., Chicago, IL 60615.

Categories

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1160330 2024-002
    Material Weakness Repeat
  • 1160331 2024-002
    Material Weakness Repeat
  • 1160332 2024-002
    Material Weakness Repeat
  • 1160333 2024-002
    Material Weakness Repeat
  • 1160334 2024-002
    Material Weakness Repeat
  • 1160335 2024-002
    Material Weakness Repeat
  • 1160336 2024-002
    Material Weakness Repeat
  • 1160337 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 Certified Community Behavioral Health Clinic Expansion Grants $876,091
93.958 Block Grants for Community Mental Health Services $686,108
93.959 Block Grants for Prevention and Treatment of Substance Abuse $451,764
14.267 Continuum of Care Program $222,627
14.241 Housing Opportunities for Persons with Aids $176,987
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $116,110
93.667 Social Services Block Grant $106,930
21.027 Coronavirus State and Local Fiscal Recovery Funds $54,259