Finding 1204848 (2025-001)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396483
Organization: Nami Chicago (IL)
Auditor: APRIO LLP

AI Summary

  • Core Issue: The Organization lacks proper documentation for expense approvals, relying on verbal confirmations instead.
  • Impacted Requirements: This violates the Uniform Guidance (2 CFR Part 200.303) for maintaining effective internal controls over federal awards.
  • Recommended Follow-Up: Update fiscal policies and procedures to ensure written approvals are required and align with Uniform Guidance standards.

Finding Text

Finding 2025-001: Disbursement Documentation - Significant Deficiency. Program name: Substance Abuse and Mental Health Services Projects of Regional and National Significance. Assistance Listing: 93.243. Federal award number: 45CBB04530. Federal award year: 7/1/2024 - 6/30/2025. Federal awarding agency: U.S. Department of Health and Human Services. Criteria - The Organization is required to follow the Uniform Guidance requirements 2 CFR Part 200.303, which requires the Organization to establish, document and maintain effective internal controls over federal awards. The Organization verbally approved expenses but lacked the documentation to support the approval. Condition - A sample of expenses were selected to test internal control over compliance and compliance with allowable costs/cost principles. Out of the items selected for testing, we noted insufficient documentation to support approval on 2 out of 40 expenses selected for testing. The exceptions noted occurred prior to the full implementation of the corrective action plan on January 1, 2025. Cause - The Organization's fiscal policies and procedures did not require written approval, leading to reliance on verbal approvals which were not documented. Effect - The failure to document approvals for expenses could lead to unallowable costs to be disbursed on grant awards. Questioned costs - None identified. Identification of Repeat Findings - This is a repeat finding from the prior year (Finding 2024-002). As a result of the 2024 audit report, issued in March 2025, the Organization began the process of developing updated policies for compliance. In 2025, the Organization formally adopted new policies and procedures that align with the internal control standards per 2 CFR Part 200. Recommendation - We recommend that management update their fiscal policies and procedures to align with what is required by the Uniform Guidance. Management response - See corrective action plan.

Corrective Action Plan

NAMI Chicago acknowledges the finding regarding documentation of approvals for expenses charged to federal awards. The exceptions identified occurred during the first half of the fiscal year, prior to the January 1, 2025, implementation of our enhanced Internal Control and Disbursement Policy developed in direct response to the FY24 audit recommendations, which were finalized and communicated in early 2025. Since January 1, 2025, NAMI Chicago has successfully implemented a mandatory digital approval workflow for all grant-funded expenditures to ensure contemporaneous documentation. Management is confident that these strengthened protocols, which were fully operational for the latter half of FY2025 and continue to date, have resolved the underlying issue. We expect no further instances of this finding in future audit cycles.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1204849 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $2.31M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $523,338
16.745 CRIMINAL AND JUVENILE JUSTICE AND MENTAL HEALTH COLLABORATION PROGRAM $208,738
93.997 ASSISTED OUTPATIENT TREATMENT $37,802
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $23,333