Finding Text
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreement Award Number: 1NH23IP922587-01 Area: Period of Performance Questioned Costs: $4,343 Criteria: In accordance with 45 CFR 75.309, a non-federal entity may charge to the federal award only allowable costs incurred during the period of performance and any costs incurred before the U.S. Department of Health and Human Services (HHS) awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Funds available to pay allowable costs during the period of performance include both federal funds awarded and the carryover balances. Condition: For two (or 8%) of twenty-five expenditures tested, aggregating $13,462, of total population of $132,807, expenditures were obligated after the end of period of performance of the related grant awards. Cause: CHCC incurred these expenditures prior to an approved PO. CHCC failed to follow the correct sequence of their PO approval process, resulting in obligating transactions after the end of the period of performance of the grant as an approved PO is required to process the payments. Effect: CHCC is in noncompliance with applicable period of performance requirements and questioned costs of $4,343 result. Identification as a Repeat Finding: Finding No. 2019-014 Recommendation: 1. CHCC should strictly follow their established policies and procedures related to PO approval, which includes checking the grant status to ensure that obligations are incurred prior to the end of the POP of the related grant. 2. CHCC should establish more stringent monitoring procedures to ensure that no expenditures are incurred prior to receiving an approval of the PO. Views of Responsible Officials: CHCC does not concur with the findings and the cost questioned. The transactions cited were for emergency repairs of Vaccine Refrigerators. The repairs were done within the period of performance ending June 30, 2020 ($2,990 was for Service date of December 20, 2019; and $1,353 was for service date February 28, 2020) No purchase order was prepared for the emergency service. A ratification memo was approved for payment processing by the Chief Financial Officer and the Chief Executive Officer. CHCC believes that the repairs on the Refrigerators that are used to store vaccines are reasonable and necessary, especially during the period wherein we are responding to the COVID-19. Auditor Response: The purchase order date, which signifies when a transaction is obligated, was beyond the period of performance. Additionally, the ratification memo was approved by the CEO on September 25, 2020, which was also beyond the period of performance. Finding remains.