Finding 1181342 (2025-001)

Material Weakness Repeat Finding
Requirement
BCL
Questioned Costs
-
Year
2025
Accepted
2026-03-18
Audit: 392561
Organization: Women for a Healthy Environment (PA)

AI Summary

  • Core Issue: Duplicate invoices were submitted for reimbursement, leading to an overdraw of $16,303 in federal funds.
  • Impacted Requirements: Lack of review and approval for reimbursement reports violates federal guidelines on preventing improper payments.
  • Recommended Follow-Up: Implement a robust internal control system for reviewing and approving costs before submission to ensure accuracy and compliance.

Finding Text

Federal Program U.S. Department of Housing and Urban Development - Healthy Homes Production Program - ALN 14.913 Criteria Under OMB guidance, Public Law (Pub. L) No. 116-117, Payments Integrity Information Act of 2019, and Executive Order 13520 on reducing improper payments, federal agencies are required to take actions to prevent improper payments, review federal awards for such payments, and as applicable, recover improper payments, including any duplicate payment. Condition While working to provide a population of invoices for audit testing, management identified five invoices that were submitted for reimbursement twice, resulting in an overdraw of federal program money. Additionally, while performing audit procedures over cash management and reporting, we noted that there was no review and approval of reports submitted for reimbursement. The Organization is required to submit quarterly reports for reimbursement. Neither of the two reports selected for testing contained evidence regarding review or approval prior to submission. Cause Duplicate invoices were submitted due to a temporary process change at the Organization when there were federal government departmental changes occurring related to federal programs. The Organization’s process change resulted in multiple people submitting reimbursement for the same expenses. We also noted that the reports were prepared based on information provided by separate personnel, but there is no review or approval in place over reports once they are combined to check for accuracy prior to submission. Effect The Organization overdrew federal program money during the fiscal year due to duplicate invoice submission, resulting in unallowable costs being charged to the program and inaccurate financial reporting. Questioned Costs $16,303 Context With changes in the process for grant funding, the Organization prioritized submission of invoices for reimbursement. During this prioritization, the Organization implemented a temporary process change, resulting in the duplicate submission errors of five invoices and the overdraw related to the federal funds. The lack of appropriate review and approval allowed the duplicate submission to occur. Repeat Finding No Recommendation We recommend that Women for a Healthy Environment establish and follow a system of internal control related to the costs charged to Federal programs. The process should establish procedures and responsibilities for the documentation and review of costs incurred and charged to Federal awards. Review and approval of this documentation should be performed by a person other than the preparer prior to submission to the Federal agency. Management Response See corrective action plan included in this report package.

Corrective Action Plan

CORRECTIVE ACTION PLAN June 30, 2025 Women for a Healthy Environment submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Herbein + Company, Foster Plaza 10, 680 Andersen Drive, Suite 205, Pittsburgh, PA 15220 Audit period: Year ended June 30, 2025 Contact: Michelle Naccarati-Chapkis, Executive Director The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section III - Federal Award Findings and Questioned Costs 2025-001 ALLOWABLE COSTS, CASH MANAGEMENT, AND REPORTING – SIGNIFICANT DEFICIENCY Federal Program U.S. Department of Housing and Urban Development - Healthy Homes Production Program - ALN 14.913 Criteria Under OMB guidance, Public Law (Pub. L) No. 116-117, Payments Integrity Information Act of 2019, and Executive Order 13520 on reducing improper payments, federal agencies are required to take actions to prevent improper payments, review federal awards for such payments, and as applicable, recover improper payments, including any duplicate payment. Condition While working to provide a population of invoices for audit testing, management identified five invoices that were submitted for reimbursement twice, resulting in an overdraw of federal money. Additionally, while performing audit procedures over cash management and reporting, we noted that there was no review and approval of reports submitted for reimbursement. The Organization is required to submit quarterly reports for reimbursement. Neither of the two reports selected for testing contained evidence regarding review or approval prior to submission. Cause Duplicate invoices were submitted due to a temporary process change at the Organization when there were federal governmental department changes occurring related to federal programs. The Organization’s process change resulted in multiple people submitting reimbursement for the same expenses. We also noted that the reports were prepared based on information provided by separate personnel, but there was no review or approval in place over reports once they are combined to check for accuracy prior to submission. Effect The Organization overdrew federal program money during the year due to duplicate invoice submission, resulting in unallowable costs being charged to the program and inaccurate financial reporting. Questioned Costs $16,303 Context With changes in the processes for grant funding, the Organization prioritized submission of invoices for reimbursement. During this prioritization, the Organization implemented a temporary process change, resulting in the duplication submission errors of five invoices and the overdraw of federal funds. The lack of appropriate review and approval allowed the duplicate submission to occur. Repeat Finding No Recommendation We recommend that Women for a Healthy Environment establish and follow a system of internal control related to the costs charged to Federal programs. The process should establish procedures and responsibilities for the documentation and review of costs incurred and charged to Federal awards. Review and approval of this documentation should be performed by a person other than the preparer prior to submission to the Federal agency. Management Response Women for a Healthy Environment has reviewed the recommendation noted above and has put additional internal controls in place related to the reimbursement drawdowns/costs charged to Federal programs. This includes ensuring that only one reimbursement is being completed each month, rather than one done at mid-month. The accounting team will continue to prepare those monthly reimbursement calculations, which will be reviewed by the Program Manager, Director of Operations, and Executive Director.

Categories

Allowable Costs / Cost Principles Cash Management

Programs in Audit

ALN Program Name Expenditures
14.913 HEALTHY HOMES PRODUCTION PROGRAM $709,811
93.197 CHILDHOOD LEAD POISONING PREVENTION PROJECTS, STATE AND LOCAL CHILDHOOD LEAD POISONING PREVENTION AND SURVEILLANCE OF BLOOD LEAD LEVELS IN CHILDREN $240,131
66.951 ENVIRONMENTAL EDUCATION GRANTS PROGRAM $100,000