Finding 1179025 (2023-009)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2023
Accepted
2026-03-12

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically regarding the timing of costs charged to the federal award.
  • Impacted Requirements: Costs must be incurred within the approved period of performance, and discrepancies between SEFA and grant records hinder compliance testing.
  • Recommended Follow-Up: Strengthen tracking of expenditures, maintain supporting documentation, reconcile records, and establish formal procedures for record retention.

Finding Text

Federal Agency: U. S. Department of Health and Human Services Cluster: Health Centers Clusters AL No.: 93.224 Program Title: Community Health Centers Area: Period of Performance Repeat Finding from Prior Audit? Yes Finding Type: Material Weakness in Internal Control over Compliance Questioned Cost: Unable to be determined Criteria: Under the OMB Compliance Supplement and Uniform Guidance (2 CFR §200.309), costs charged to a federal award must be incurred within the approved period of performance unless otherwise authorized by the federal awarding agency or pass-through entity. Specifically: • Costs recorded at the beginning of the period of performance must not have been incurred prior to the start date unless authorized. • Costs recorded near or after the end of the period of performance must have been incurred within the approved performance period. • Obligations not liquidated as of the end of the period of performance must be liquidated within the time period allowed by applicable regulations. Condition: No expenditure selections were tested for period of performance compliance. The auditors were unable to identify a reliable population of expenditures to test due to discrepancies between the SEFA and underlying grant expense records. Cause: The amount per SEFA for AL No. 93.224 did not reconcile to grant expense records, and supporting documentation for program-specific expenditures was not sufficiently available. Additionally, the absence of a formal turnover of accounting and grant records following personnel changes limited the availability of information necessary to identify a complete and accurate population for testing. Effect: Because no expenditures were tested, the auditors were unable to determine whether costs charged to AL No. 93.224 were incurred within the approved period of performance or whether obligations were liquidated within allowable timeframes. This increases the risk that costs incurred outside the period of performance may have been charged to the program and weakens internal controls over compliance with federal award requirements. Recommendation: Kagman Community Health Center, Inc. should strengthen internal controls over period of performance compliance by: 1. Ensuring that expenditures are accurately tracked by federal program and period of performance. 2. Maintaining documentation that clearly supports the timing of costs incurred and the liquidation of obligations. 3. Reconciling grant expense records to the SEFA to allow identification of a complete population for compliance testing. 4. Establishing formal turnover and record-retention procedures to ensure continuity of grant accounting documentation. Views of the Officials: Kagman Community Health Center, Inc.’s response is documented in the corrective action plan.

Corrective Action Plan

Corrective Action Plan Action Item Responsible Party Monitoring Require that federal grant expenditures be tracked by program and period of performance to ensure costs are incurred within approved timeframes. CFO / Grants Accounting Monthly review Maintain supporting documentation to substantiate the timing of costs incurred and the liquidation of obligations in accordance with federal requirements. CFO / Accounting Staff Periodic internal review Reconcile grant expense records to the SEFA to ensure a complete and reliable population for compliance testing. CFO Documented reconciliation In FY 2026, management developed and implemented a formal Records Retention Policy to ensure that accounting records, supporting documentation, and organizational records are properly maintained and retained in accordance with applicable regulatory and audit requirements. CFO Management oversight Implement supervisory review of grant expenditures to confirm compliance with performance requirements. CFO / Board Finance Committee Quarterly review ________________________________________ Management Response Management notes that no additional federal grants, other than the HRSA Section 330 program grant (Assistance Listing 93.224), were received in FY2025 or FY2026. Prior management did not provide a reconciled SEFA schedule for earlier reporting periods, which contributed to the documentation limitations identified during the audit. Beginning in FY2026, management has developed a detailed SEFA tracking schedule for the HRSA Section 330 grant that identifies the date federal funds were drawn down, the amount received, the related expenditures, and the corresponding disbursement dates. This schedule is maintained to improve reconciliation between drawdowns, expenditures, and the general ledger and to ensure documentation is readily available for audit and compliance purposes. In FY2026, management implemented an updated and comprehensive set of policies and procedures designed to strengthen internal controls and promote consistent, standardized accounting and administrative practices. These updates establish clearer documentation requirements, defined responsibilities, and improved oversight to ensure compliance with applicable regulations and the safeguarding of organizational records and financial information. ________________________________________ Responsible Official: Chief Financial Officer Expected Completion Date: FY 2026

Categories

Period of Performance

Other Findings in this Audit

  • 1179022 2023-006
    Material Weakness Repeat
  • 1179023 2023-007
    Material Weakness Repeat
  • 1179024 2023-008
    Material Weakness Repeat
  • 1179026 2023-010
    Material Weakness Repeat
  • 1179027 2023-011
    Material Weakness Repeat
  • 1179028 2023-011
    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) $2.49M
93.225 NATIONAL RESEARCH SERVICE AWARDS HEALTH SERVICES RESEARCH TRAINING $139,026
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $72,668