Finding 1168197 (2024-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-01-07

AI Summary

  • Core Issue: The Organization failed to maintain consistent documentation for federal fund drawdowns, leading to potential misalignment with actual expenditures.
  • Impacted Requirements: Compliance with federal cash management rules under Uniform Guidance (2 CFR §200.305) was not met, risking over- or under-drawdowns.
  • Recommended Follow-Up: Establish stronger internal controls and procedures to ensure timely reconciliation of drawdowns with actual expenses and maintain complete supporting documentation.

Finding Text

Criteria – Uniform Guidance (2 CFR §200.305) requires that non-federal entities establish and maintain written procedures to minimize the time elapsing between the transfer of federal funds from the U.S. Treasury and the disbursement of those funds for allowable program expenditures. In addition, entities must maintain adequate documentation to support all drawdowns and ensure that amounts requested are based on actual, allowable costs incurred. Condition and Description – During our audit, we identified deficiencies in the Organization’s compliance with federal cash management requirements and internal controls over reporting of federal expenditures. Specifically, documentation supporting certain drawdowns of federal funds was not consistently maintained. However, the total drawdowns did not exceed eligible expenses. In addition, we noted timing differences between when expenses were recognized in the financial statements and when related drawdowns were requested and reported to the federal government. These conditions create the risk that federal funds may not be drawn down in alignment with actual expenditures, resulting in temporary over- or under-drawdowns, increasing the likelihood of noncompliance with Uniform Guidance requirements and misstatements of federal program expenditures. Questioned Costs – Unknown. Cause/Effect – Drawdowns were not consistently reconciled to underlying expenses, and supporting documentation was incomplete. Timing differences between expenditures and drawdowns were not addressed, creating the risk of temporary over- or under-drawdowns and noncompliance with federal cash management requirements.

Corrective Action Plan

AHC has fully implemented enhanced reconciliation procedures to ensure that all grant drawdowns are reconciled to the general ledger prior to submission, with supporting documentation retained electronically. Quarterly internal audits of drawdown packets are conducted to ensure compliance with federal requirements. These improvements eliminate timing discrepancies and strengthen federal cash management controls. All federal expenditures year-to-date have been verified. It is important to note that AHC did not maintain a single consolidated record of drawdown support but instead retained multiple supporting documents. Despite this documentation issue, all drawdowns were found to be in compliance with HRSA guidelines and were determined to represent allowable costs.

Categories

Cash Management Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1168195 2024-002
    Material Weakness Repeat
  • 1168196 2024-002
    Material Weakness Repeat
  • 1168198 2024-003
    Material Weakness Repeat
  • 1168199 2024-003
    Material Weakness Repeat
  • 1168200 2024-003
    Material Weakness Repeat
  • 1168201 2024-003
    Material Weakness Repeat
  • 1168202 2024-003
    Material Weakness Repeat
  • 1168203 2024-003
    Material Weakness Repeat
  • 1168204 2024-004
    Material Weakness Repeat
  • 1168205 2024-004
    Material Weakness Repeat
  • 1168206 2024-004
    Material Weakness Repeat
  • 1168207 2024-005
    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) $5.00M
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $52,769
93.800 ORGANIZED APPROACHES TO INCREASE COLORECTAL CANCER SCREENING $42,000
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $14,425