Finding 1163217 (2024-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-12-01

AI Summary

  • Core Issue: Timely payments to subrecipients are not being made, with 5 out of 18 billings paid late.
  • Impacted Requirements: Violations of 2 CFR section 200.305(b)(1) and (b)(3) regarding payment timelines.
  • Recommended Follow-Up: Establish clear policies to ensure payments are made within 30 days of billing receipt.

Finding Text

Criteria or specific requirement: 2 CFR section 200.305(b)(1) requires that an entity implement procedures to ensure that the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient be minimized. 2 CFR section 200.305 (b)(3) states the pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the request is believed to be improper. Condition: 5 out of 18 total billings sampled were not paid timely. Questioned costs: None. Context: During our testing of subrecipient payments, 5 out of the 18 billings sampled were not paid within 30 calendar days to the subrecipient after the billing was submitted for payment. Cause: Policies and procedures were not in place to ensure timely payments of subrecipient billings. Effect: Subrecipients received payments a significant amount of time after expenditures have been incurred. Repeat Finding: Yes. Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have established a process to review and track accounts payable, including monthly reviews of outstanding bills, partner invoices, and partner compliance. Furthermore, we have added additional accounting staff focused on disbursements for subrecipients involved in federal grant programs. Finally, we have a process in place to document the receipt of partner invoices submitted to GHN for payment as well as a record of payment approval and/or revisions necessary. Names of the contact persons responsible for corrective action: Jan Warren, Director of Finance & Amber Henderson, Chief Organization Excellence & Strategy Officer Planned completion date for corrective action plan: December 31, 2025

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1163218 2024-003
    Material Weakness Repeat
  • 1163219 2024-004
    Material Weakness Repeat
  • 1163220 2024-005
    Material Weakness Repeat
  • 1163221 2024-006
    Material Weakness Repeat
  • 1163222 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $1.86M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $694,987