Finding 1203106 (2025-003)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2025
Accepted
2026-03-30

AI Summary

  • Core Issue: The Organization lacks a formal process to verify that expenses charged to federal programs are incurred within the approved grant period.
  • Impacted Requirements: Compliance with 2 CFR 200.309, which mandates that only allowable costs during the approved period can be charged to federal awards.
  • Recommended Follow-Up: Implement a robust monitoring process for reviewing expenditures, especially at the start and end of grant periods, to ensure compliance.

Finding Text

Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number: H80CS00824-24 Award Periods: May 1, 2025 – April 30, 2026 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: Per 2 CFR 200.309, federal award recipients may charge to the federal award only allowable costs incurred during the approved period of performance. The auditee is responsible for establishing and maintaining effective internal control procedures to ensure expenditures charged to federal programs are incurred within the approved grant period. Condition: We noted the Organization did not have a formal process to review expenditures charged to federal programs to ensure they were incurred within the applicable period of performance. Specifically, management did not maintain documentation or a monitoring process to verify that expenditures recorded near the beginning or end of the grant period were incurred within the authorized period of performance. Questioned Costs: $6,504 Context: Seven (7) and of the eleven (11) transactions selected for testing related to expenditures incurred outside the period or performance. Cause: The Organization did not have a formal policy and procedure to closely review the expense charged to the grant during the first and last months of the grant period. Effect: Without adequate controls over period of performance, there is an increased risk that expenditures could be charged to federal awards outside the approved grant period. Repeat Finding: No. Recommendation: We recommend the Organization implement a comprehensive and thorough process to review and monitor expenditures charged near the beginning and end of grant periods to ensure the expenditures incurred are within the authorized federal award grant period.

Corrective Action Plan

Period of Performance Health Centers Cluster – Assistance Listing No. 93.224 and 93.527 Recommendation: We recommend the Organization implement a comprehensive and thorough process to review and monitor expenditures charged near the beginning and end of grant periods to ensure the expenditures incurred are within the authorized federal award grant period. Action taken in response to finding: A procedure was implemented March 2026 to perform an internal audit of the expenditures charged within the pre-and-post 30 days of a grant year transition to ensure expenses are occurring within the appropriate grant year prior to draw submission and will continue moving forward. A remedy of $87,554.96 was implemented over two grant draws within the grant year to address the population of period of performance crossing expenses. Name(s) of the contact person(s) responsible for corrective action: John Robinson, CFO Planned completion date for corrective action plan: New policy and procedure implemented in March 2026 and will be carried forward.

Categories

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1203105 2025-002
    Material Weakness Repeat
  • 1203107 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $1.80M
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $276,096
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $79,960
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $25,000