Finding 11725 (2023-001)

2023‐001 – Written Policies Required by the Uniform Guidance Finding Type. Immaterial Noncompliance; Significant Deficiency In Internal Controls Over Compliance (Allowable Costs/Cost Principles and Cash Management) Federal program(s): U.S. Department of Health and Human Services: -COVID‐19 ‐ Provider Relief Fund; Assistance Listing Number 93.498; Passed through the Ohio Department of Medicaid (OMD) -Block Grants for Community Mental Health Services; Assistance Listing Number 93.958; Passed through the Substance Abuse and Mental Health Services Administration (SAMSHA) Criteria. The Uniform Guidance requires a non‐federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318) 3) Allowability of costs charged to federal programs (§200.302(7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although Unison has processes in place to cover these areas, there are no formal written policies for payments and allowability of costs charged to federal programs. Cause. This condition appears to be the result of an oversight in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, Unison did not fully comply with the Uniform Guidance applicable to its federal payments received and the allowability of such payments. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that Unison develop and adopt formal written policies, in accordance with the Uniform Guidance. View of Responsible Officials. Management agrees with this finding and has prepared a corrective action plan.