Finding 1166286 (2023-003)

Certified Community Behavioral Health Clinic Expansion Grants Assistance Listing Number 93.696 U.S. Department of Health and Human Services Criteria or Specific Requirement – Cash Management (45 CFR 75.305) Condition – The Organization’s internal controls over compliance were not able to prevent an advance drawdown. Cause – The Organization was struggling to maintain adequate cash reserves and therefore advance drew on the award, with the knowledge that allowable expenditures would be incurred and covered by the draw in future periods. Effect or potential effect – Grant funds were drawn down sooner than administratively necessary. The one draw was not earned as of the end of three days prior to disbursement of allowable expenditures. Questioned Costs – None Context – Out of a population of sixteen draws, a sample of four draws were selected for testing. The sampling methodology used was not, and was not intended to be, statistically valid. Of the four draws tested, one draw was considered advanced Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should ensure procedures are followed to prevent cash draws from being drawn sooner than three days prior to disbursement of allowable expenditures.