Finding 1215566 (2025-003)

Material Weakness Repeat Finding
Requirement
BH
Questioned Costs
-
Year
2025
Accepted
2026-05-26
Audit: 402238
Organization: Change Happens! (TX)

AI Summary

  • Core Issue: Significant deficiencies in internal controls led to costs being charged outside the allowed grant periods, totaling approximately $8,896 in questioned costs.
  • Impacted Requirements: Non-compliance with Uniform Guidance regarding allowable costs and the period of performance for federal funding.
  • Recommended Follow-Up: Reinforce adherence to internal policies for reviewing payroll and transaction coding to prevent future non-compliance.

Finding Text

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract # NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Criteria: Allowable costs and period of performance – The Uniform Guidance, Subpart E Cost Principles, establishes costs principles which must be followed for expenditures to be allowable and requires a system of internal controls sufficient to ensure that costs are properly charged to the appropriate general ledger object and class code. The Uniform Guidance §200.309 period of performance requires expenditures be incurred during the period of the federal grant award in order to be allowable. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost and other non-compliance: AL #93.092 Affordable Care Act (ACA) Personal Responsibility Education Program. In a sample of 40 non-payroll transactions tested for internal controls and compliance for allowable cost we found one instance of an annual subscription for the term ending May 2026 charged to a grant which ended September 29, 2025 resulting in eight months, or approximately $1,200, charged outside the period of performance. Partial repeat of finding #2024-004. Controls over period of performance and other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges. In a period-of-performance sample of 18 vendor transactions with grant charges close to grant beginning or ending dates during the audit period, we found 3 instances or $1,003 of vendor costs charged outside the grant period of performance. Additionally, testing of payroll charged at the end of the grant period revealed that approximately $6,693 was charged outside the period of performance. Cause and Effect: Failure to follow Civic Heart’s policies and procedures related to review of coding for charges to the grants resulted in costs charged outside the grant’s period of performance. Questioned costs: $8,896. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance and review of payroll spreadsheets and general ledger coding for all transactions. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract # NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost and other non-compliance: AL #93.092 Affordable Care Act (ACA) Personal Responsibility Education Program. In a sample of 40 non-payroll transactions tested for internal controls and compliance for allowable cost we found one instance of an annual subscription for the term ending May 2026 charged to a grant which ended September 29, 2025 resulting in eight months, or approximately $1,200, charged outside the period of performance. Partial repeat of finding #2024-004. Controls over period of performance and other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges. In a period-of-performance sample of 18 vendor transactions with grant charges close to grant beginning or ending dates during the audit period, we found 3 instances or $1,003 of vendor costs charged outside the grant period of performance. Additionally, testing of payroll charged at the end of the grant period revealed that approximately $6,693 was charged outside the period of performance. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance and review of payroll spreadsheets and general ledger coding for all transactions. Planned corrective action: Management has implemented strengthened procedures related to payroll allocations, grant coding, allowable costs review, and monitoring of grant periods of performance. Corrective actions include: 1) Enhanced review procedures to ensure expenditures are charged to the appropriate funding source and grant period. 2) Review of payroll allocations against approved grant budgets and supporting time and effort certifications where applicable. 3) Monthly review meetings between finance personnel and program leadership to review coding accuracy, budget status, payroll allocations, and grant compliance requirements. 4) Additional staff training related to Uniform Guidance cost principles, allowable costs, grant periods of performance, and GAAP financial reporting requirements. 5) Improved grant expenditure tracking and monitoring procedures to identify coding errors or compliance concerns timely. 6) Strengthened documentation retention procedures to ensure expenditures are properly supported and audit ready. Responsible officer: Anita Bates, Chief Executive Officer. Estimated completion date: Implementation is underway with continued monitoring and expected to be fully operational by August 31, 2026.

Categories

Allowable Costs / Cost Principles Period of Performance HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1215562 2025-002
    Material Weakness Repeat
  • 1215563 2025-003
    Material Weakness Repeat
  • 1215564 2025-004
    Material Weakness Repeat
  • 1215565 2025-002
    Material Weakness Repeat
  • 1215567 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $1.75M
14.267 CONTINUUM OF CARE PROGRAM $1.17M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $463,974
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $411,928
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $386,556
93.060 SEXUAL RISK AVOIDANCE EDUCATION $248,060
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $241,013
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $186,733
16.830 REDUCING RECIDIVISM FOR FEMALE JUVENILE DELINQUENTS $114,229
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $69,070
16.548 DELINQUENCY PREVENTION PROGRAM $30,853