Finding 1176972 (2023-006)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2026-03-09
Audit: 390799
Organization: Papa Ola Lokahi (HI)
Auditor: KKDLY LLC

AI Summary

  • Core Issue: The Organization lacks internal controls over cash management for federal payments, risking noncompliance with regulations.
  • Impacted Requirements: Compliance with 2 CFR §200.305, which mandates minimizing the time between federal fund transfers and recipient disbursements.
  • Recommended Follow-Up: Implement internal controls to review payment requests and disbursements to ensure adherence to federal cash management requirements.

Finding Text

Material Weakness Finding No. 2023-006: Cash Management U.S. Department of Education Native Hawaiian Education Act Program Federal Assistance Listing Number 84.362A. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria Pursuant to 2 CFR §200.305, the payment methods for Federal payments to recipients must minimize the time elapsing between the transfer of funds from the Federal agency to the recipient and the disbursement of funds by the recipient. Condition We noted that the Organization’s director of administrative operations has implemented a methodology designed to minimize the time that advance payment requests are expended; however there are no internal controls in place over this process. Cause The Organization’s policies and procedures do not require an internal review of the payment requests and the subsequent disbursements of the Federal funds to ensure compliance with 2 CFR §200.305. Effect The lack of internal controls could result in noncompliance with 2 CFR §200.305. Recommendation We recommend that the Organization incorporate internal controls over cash management to ensure compliance with 2 CFR §200.305.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action The Organization notes the following existing internal control practices, as it relates to cash management subsequent policy and process development and implementation, and the additional controls to be implemented: A. System, Process & Review Controls In Practice. 1. System Controls. The Organization operates in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. 2. Process & Review Controls – EHB & PMS. Cash management requests (aka federal draws) are computed by, and entered into the EHB, including the Organization’s justification of the expenditure, by the director of administrative operations, including the CEO on the approval request. The propriety of the cash draw is reviewed by the HHS assigned grants management specialist; and inquiry action, if needed, documented by e-mail from the grants management specialist; and approval documented in the EHB. Once the draw is approved, the director of administrative operations enters information into the PMS, noting that the CEO, is the authorized organization representative (AOR). The grants management specialist must then approve the draw request once more in the PMS system before a PMS representative approves the draw request. 3. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls include review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds – Additional Information and Statistics, Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). B. Internal Control Environment Policy Establishment – July 2025. In July 2025, the Organization developed the following cash management related policies and related procedures: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; Implementation of HRSA Related Policies, including cash management processes and procedures. C. Additional Process & Review Controls – March 2026. Beginning March 2026, for federal draws, process and review internal controls will be implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively.

Categories

Cash Management Material Weakness

Other Findings in this Audit

  • 1176963 2023-002
    Material Weakness Repeat
  • 1176964 2023-003
    Material Weakness Repeat
  • 1176965 2023-004
    Material Weakness Repeat
  • 1176966 2023-005
    Material Weakness Repeat
  • 1176967 2023-006
    Material Weakness Repeat
  • 1176968 2023-002
    Material Weakness Repeat
  • 1176969 2023-003
    Material Weakness Repeat
  • 1176970 2023-004
    Material Weakness Repeat
  • 1176971 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.932 NATIVE HAWAIIAN HEALTH CARE SYSTEMS $5.61M
84.362A NATIVE HAWAIIAN EDUCATION $711,178
93.011 NATIONAL ORGANIZATIONS FOR STATE AND LOCAL OFFICIALS $143,172
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $117,660
93.387 NATIONAL AND STATE TOBACCO CONTROL PROGRAM $110,263
93.426 THE NATIONAL CARDIOVASCULAR HEALTH PROGRAM $72,971
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $56,604
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $35,481
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION’S HEALTH $30,763
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $24,589
93.334 THE HEALTHY BRAIN INITIATIVE: TECHNICAL ASSISTANCE TO IMPLEMENT PUBLIC HEALTH ACTIONS RELATED TO COGNITIVE HEALTH, COGNITIVE IMPAIRMENT, AND CAREGIVING AT THE STATE AND LOCAL LEVELS $9,374