Finding 1164259 (2024-001)

Material Weakness Repeat Finding
Requirement
ABL
Questioned Costs
-
Year
2024
Accepted
2025-12-09
Audit: 373559
Organization: Hiv Alliance INC (OR)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to the review and approval of indirect costs and quarterly reports for federal funds.
  • Impacted Requirements: The lack of documentation violates 2 CFR 200.303(a), which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Emphasize the need for proper documentation of approvals and provide training on consistent application of internal control procedures.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Opioid STR; Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.788, 93.959 Federal Award Identification Number and Year: 167552 - 2024 Pass-Through Agency: Oregon Health Authority Pass-Through Number(s): 167552 Award Period: January 4, 2021, through September 29, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Criteria or specific requirement: 2 CFR 200.303(a) states that a non-federal entity must "Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Condition: During our testing we noted that documentation of the review and approval process for indirect costs charged to federal funds, as well as for quarterly reports, was not retained. Questioned costs: None. Context: CLA tested four billing reconciliations that were prepared to recognize the true revenue. For one billing reconciliation, no evidence of review and approval of the indirect cost charged to federal fund (i.e. monthly journal entries) were retained. For all quarterly reporting samples tested (two), no evidence of review and approval was retained to ensure reports are accurate. Cause: Inconsistent application of internal controls procedures. Effect: Without adequate controls in place to ensure costs are accurate, it may result in misappropriation of funds and noncompliance with grant regulations, which could result in penalties or repayment obligations. Repeat Finding: No Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by the Alliance as proof of oversight of expenditure of federal funds. Additionally, CLA recommends increased emphasis and training on the importance of consistent application of procedures and controls. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Health and Human Services Significant Deficiency in Internal Controls over Compliance: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by the Alliance as proof of oversight of expenditure of federal funds. Additionally, CLA recommends increased emphasis and training on the importance of consistent application of procedures and controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All reports relating to a federally funded project will be reviewed prior to being submitted to the funding agency and documentation relating to that review will be retained by HIV Alliance. Name(s) of the contact person(s) responsible for corrective action: Renee Yandel, Executive Director; Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1164257 2024-001
    Material Weakness Repeat
  • 1164258 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.788 OPIOID STR $724,131
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $625,811
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $207,581
93.928 SPECIAL PROJECTS OF NATIONAL SIGNIFICANCE: Operation of Intervention Site Provided Behavior Health Services to Individuals Affected by Aids $190,838
93.211 TELEHEALTH PROGRAMS $122,540
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $55,819
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED: Linkage to Care for Diagnosed HIV Positive Individuals $19,373
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $17,124
93.917 HIV CARE FORMULA GRANTS $1