Finding 1162291 (2024-004)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2024
Accepted
2025-11-13
Audit: 372114
Organization: Waikiki Health (HI)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: Internal controls over cash disbursements were not consistently followed, leading to unapproved charges to federal awards.
  • Impacted Requirements: Compliance with 2CFR 200.303(a) is at risk, potentially resulting in unallowable costs and noncompliance with grant terms.
  • Recommended Follow-Up: Implement a robust system for ensuring all cash disbursements receive proper approval, as outlined in the management's Corrective Action Plan.

Finding Text

Finding 2024.004: Allowable Costs/Activities Allowed or Unallowed - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 - Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Assistance Listing Numbers: 93.224 Federal Award Identification Number and Year: H80CS00053 - 2023 and 2024, H8FCS41422 - 2023 Criteria In accordance with 2CFR 200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The specific allowability requirements are unique to each federal program, in accordance with the terms and conditions of the federal award pertaining to the program. Condition Charges to federal awards for cash disbursements were not supported by illustration of proper approval. Cause The Center’s internal controls over cash disbursements were not consistently followed to ensure invoices were properly approved. Effect or Potential Effect Failure to ensure cash disbursements across programs have proper approval could result in noncompliance with the grant requirements or unallowable costs being charged. Questioned Costs None Context A test of 25 cash disbursement transactions was performed and resulted in four instances where the Center was unable to provide approved documentation. Our sample was a statistically valid sample. Identification of Repeat Finding This finding is a repeat finding (see prior year finding number: 2023.004) Recommendation The Center should establish a system of internal controls to ensure that all cash disbursements are properly approved. Views of Responsible Officials and Planned Corrective Actions Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency. Management has prepared a Corrective Action Plan that outlines the additional controls implemented.

Corrective Action Plan

Finding 2024.004 -Allowable Costs/Activities Allowed or Unallowed Recommendation The Center should establish a system of internal controls to ensure that all cash disbursements are properly approved. Action Taken In response to the audit finding, I will, in collaboration with the Chief Executive Officer, develop and implement a comprehensive internal control system to ensure that all cash disbursements are properly reviewed and approved before processing. We will create a formal disbursement approval policy that outlines required documentation, approval thresholds, and designated approvers based on transaction type and amount. All disbursement requests must now be accompanied by supporting documentation (e.g., invoices and/or contracts) and routed through a multi-level approval workflow within our accounting system.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1162286 2024-003
    Material Weakness Repeat
  • 1162287 2024-004
    Material Weakness Repeat
  • 1162288 2024-005
    Material Weakness Repeat
  • 1162289 2024-006
    Material Weakness Repeat
  • 1162290 2024-003
    Material Weakness Repeat
  • 1162292 2024-005
    Material Weakness Repeat
  • 1162293 2024-006
    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) $358,035
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $189,487