Finding 1161572 (2024-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-10-29

AI Summary

  • Core Issue: Internal controls failed to prevent the purchase of pharmaceutical products that could be used for abortion, violating federal regulations.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) regarding effective internal control over federal awards and allowable costs.
  • Recommended Follow-Up: Enhance processes and controls to better identify and prevent unallowable costs from being charged to the program.

Finding Text

U.S. Department of Health and Human Services Federal Financial Assistance Listing 93.217 Family Planning Services Project Grant – FPHPA006544 Allowable Costs Significant Deficiency in Internal Control over Compliance and Immaterial Instance of Noncompliance 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 Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award, including with respect to allowable costs. Condition: In connection with the audit performed, an instance was noted of funds maintained by the entity’s grants division being used to purchase pharmaceutical products that could be used for abortion purposes (as prohibited by 42 CFR section 59.5(a)(5)). The Organization’s policy is to not purchase such products through the entity’s grants division. Cause: The Organization’s internal controls did not detect the error. Effect: There is an increased risk of noncompliance when internal controls are not adequately established, followed, and documented relating to allowable costs requirements. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used for testing this compliance requirement. Sample size was 60 transactions out of 3,500 total program transactions and included $144,939 out of $7,661,509 expenses. There was one error noted during our testing and it was noted that $1,124 of costs charged to the program were used for costs that could be used for unallowable purposes. Repeat Finding from Prior Year(s): No Recommendation: The Organization should improve its processes and controls for identifying costs that do not meet the criteria to be purchased. Views of Responsible Officials: Management agrees with this finding.

Corrective Action Plan

Review AP policies, train AP personnel, and require double approval before using grant funds

Categories

Allowable Costs / Cost Principles Procurement, Suspension & Debarment HUD Housing Programs Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.217 FAMILY PLANNING_SERVICES $3.15M
97.008 NON-PROFIT SECURITY PROGRAM $100,000
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $68,668
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $44,196
93.974 FAMILY PLANNING_SERVICE DELIVERY IMPROVEMENT RESEARCH GRANTS $6,500