Finding Text
Finding No.: 2023-018 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: Compact of Free Association, As Amended Questioned Costs: $0 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Federal Award No.: NU50CK000558 Questioned Costs: $0 Area: Reporting Criteria: Grant agreements stipulate the type and frequency of reports to be submitted. Furthermore, timely, accurate and complete reporting should be facilitated by an internal control structure conducive to the monitoring, preparation and independent review of required reports. Lastly, financial reports should reconcile with underlying accounting records. Furthermore, 2 CFR 200.303(a) states that a recipient of a Federal award must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition 1: There are no policies and procedures requiring monitoring of reports to be submitted or listing of reports already submitted. It does not appear that RepMar has developed means to monitor compliance with reporting requirements. Condition 2 (ALN 15.875): Of 46 financial reports due in fiscal year 2023, we noted the following: a) For 20 (or 43%), the reports were not available for examination: Item # Fund # SPG Code Award # Quarter End Due Date Date Submitted 1 10406 70150200 D22AF00005-00 12/31/2022 01/30/2023 unknown 2 10406 70210100 D23AF00077-00 12/31/2022 01/30/2023 unknown 3 10406 70210200 D23AF00077-00 12/31/2022 01/30/2023 unknown 4 10406 70210400 D23AF00077-00 12/31/2022 01/30/2023 unknown 5 10409 70041000 D23AF00011-00 12/31/2022 01/30/2023 unknown 6 10409 70190100 D23AF00050-00 12/31/2022 01/30/2023 unknown 7 20103 70060100 D23AF00024-00 12/31/2022 01/31/2023 unknown 8 20103 70060101 D23AF00041-00 03/31/2023 04/30/2023 unknown 9 10406 70340103 D22AF00004-00 03/31/2023 04/30/2023 unknown 10 10408 70090100 D23AF00009-00 03/31/2023 04/30/2023 unknown 11 10409 70040600 D23AF00011-00 03/31/2023 04/30/2023 unknown 12 10409 70040700 D23AF00011-00 03/31/2023 04/30/2023 unknown 13 10409 70040900 D23AF00011-00 03/31/2023 04/30/2023 unknown 14 10409 70041000 D23AF00011-00 03/31/2023 04/30/2023 unknown 15 10409 70120100 D23AF00037-00 03/31/2023 04/30/2023 unknown 16 10409 70290100 D22AF00006-00 03/31/2023 04/30/2023 unknown 17 10409 71480000 D24AF00024 03/31/2023 04/30/2023 unknown 18 10412 70080300 D23AF00027 03/31/2023 04/30/2023 unknown 19 10412 70140100 D22AF00007-00 03/31/2023 04/30/2023 unknown Item # Fund # SPG Code Award # Quarter End Due Date Date Submitted 20 10412 70140200 D22AF00007-00 03/31/2023 04/30/2023 unknown b) For 3 (or 7%), SF-425 reports do not align with the underlying FMIS expenditure report: Item # Fund # SPG Code Award # Quarter End SF-425 Amount 240P Amount Difference 1 410100 all cost centers D22AF00003-00 FY22 annual $713,140 $819,340 ($ 106,200) 2 10409 70290100 D22AF00006-00 06/30/2023 5,743,454 6,063,193 (319,739) 3 20103 70060101 D23AF00041-00 7/30/2023 20,137,770 20,328,571 (190,801) ($ 616,740) Condition 3 (ALN 15.875) For the Four Atolls Health Care program, we were unable to ascertain compliance with reporting requirements due to lack of grant agreement as reported in Finding No. 2023-015. Further, a second grant agreement (D23AP00058-01) covering the period from 02/02/2023 through 09/30/2027 was available for examination, however, the grant terms and conditions attachment was not included. Condition 4 (ALN 93.323): RepMar uses the ELC Cooperative Agreement Management Platform (CAMP) portal to report financial progress to the Federal grantor. RepMar was unable to provide evidence that such reporting occurred during the audit period. Furthermore, no evidence was provided indicating that the financial information reported thereon agreed to RepMar's underlying accounting records. Cause: RepMar lacks adequate internal control policies and procedures governing monitoring, preparation and independent review of required reports. Moreover, RepMar lacks adequate internal control policies and procedures over retention of all grant agreements, copies of reports submitted to grantors, and the underlying accounting records. Effect: Sufficient appropriate audit evidence supporting compliance with applicable reporting requirements were not obtained which results in report modification. No questioned cost is reported as the condition relates to inadequacy of internal control policies and procedures governing monitoring, preparation, independent review and retention of required reports and underlying accounting records. Identification as a Repeat Finding: Finding Nos. 2022-009. Recommendation: RepMar should establish adequate internal control policies and procedures governing monitoring, preparation and independent review of required reports. Moreover, RepMar should establish internal control policies and procedures requiring retention of all grant agreements and copies of reports submitted to grantors. Views of Responsible Officials: RepMar’s Corrective Action Plan does not indicate disagreement and provides planned corrective action.