Finding 1176625 (2025-008)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-05

AI Summary

  • Core Issue: Subrecipient payments were incorrectly made directly to vendors instead of to the subrecipients.
  • Impacted Requirements: This practice violates 2 CFR Part 200, which mandates that funds must be disbursed to subrecipients to ensure proper oversight and compliance.
  • Recommended Follow-Up: The Association should establish formal policies to ensure that federal funds are sent directly to subrecipients, enhancing compliance and accountability.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Project Funding/Congressionally Directed Spending ‐ Construction Assistance Listing Number: 93.493 Federal Award Identification Number and Year: 6-CE1HS52375-07 - 2023 Award Period: September 30, 2023, through September 29, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance – Cash Management – Subrecipient Payments • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.305 specifies that payments to subrecipients must minimize the time between the transfer of funds and their disbursement for program purposes. Subrecipients must be able to demonstrate proper use of funds, maintain records, and be subject to audit. Condition: During testing, it was noted that subrecipient payments were being directly remitted to vendors rather than subrecipients. Questioned costs: None. Context: Of the thirteen samples selected for testing, we noted that nine samples were paid directly to the vendor, rather than the subrecipient. Cause: The Association did not have internal controls in place to ensure subrecipient payments were being remitted directly to the subrecipients. Effect: The Association is noncompliant with federal regulations related to the federal award. Subrecipients do not receive or manage the federal funds, undermining their responsibility for programmatic and financial oversight. Repeat Finding: N/A. Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management Material Weakness

Other Findings in this Audit

  • 1176619 2025-002
    Material Weakness Repeat
  • 1176620 2025-003
    Material Weakness Repeat
  • 1176621 2025-004
    Material Weakness Repeat
  • 1176622 2025-005
    Material Weakness Repeat
  • 1176623 2025-006
    Material Weakness Repeat
  • 1176624 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.493 Community Project Funding/Congressionally Directed Spending ‐ Construction $2.11M