Finding 1213598 (2025-003)

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224 Federal Award Identification Number: H8000517; H8NCS54087 Award Periods: July 1, 2024 – February 28, 2025; March 1, 2025 – June 30, 2025 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Clinic was unable to provide documentation that a formal review and approval process had occurred prior to initiating drawdowns via the payment management system. Questioned Costs: None Context: This condition was identified during the review and testing of drawdowns as part of testing cash management. Cause: The Clinic has a limited number of resources in its finance department and as a result has incorporated the executive director into the review process. However, documentation was not created and maintained to shown that a formal review and approval had occurred prior to initiation drawdowns. Effect: The lack of documented review increases the risk that noncompliance with federal requirements could occur and not be prevented or detected in a timely manner. Repeat Finding: No. Recommendation: We recommend the Clinic develop and implement a formal review and approval process related to drawdowns. This should include the creation and maintaining of supporting documentation which demonstrates who performed the review and when it was performed. This could be done via sign-offs, checklists, or electronic approvals.