Finding 1215567 (2025-004)

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

AI Summary

  • Core Issue: Civic Heart failed to reconcile federal expenditures, leading to significant errors in the Schedule of Expenditures of Federal Awards (SEFA).
  • Impacted Requirements: Noncompliance with Uniform Guidance reporting standards, including lack of identification for subrecipient expenditures and absence of independent SEFA review.
  • Recommended Follow-up: Reinforce adherence to policies for regular reconciliation of federal expenditures and establish a formal independent review process for the SEFA and grant billings.

Finding Text

Finding #2025-004 – 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: Reporting – The Uniform Guidance §200.508 and §200.510 requires management to prepare a schedule of expenditures of federal wards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended and amounts expended by subrecipients. Management is responsible for establishing and maintaining an effective system of internal control sufficient to prepare the SEFA in accordance with Uniform Guidance. Condition and context: Civic Heart had not performed a reconciliation of federal expenditures resulting in errors in reported expenditures. Additionally, subrecipient expenditures were not identified for two programs. There was no independent review of the SEFA. During the audit of the 2025 fiscal year, it was noted that the SEFA for the year ended August 31, 2024 overstated expenditures for the HIV Prevention Activities – Non-Governmental Organizational Based program (AL #93.939) by $52,013. The 2024 SEFA included expenditures that were allowable in accordance with the grant agreement but not billed to the federal agency for reimbursement. An audit adjustment reducing the current year expenditures was required. Cause: Transitions in the accounting and management team resulted in failure to follow Civic Heart’s policies and procedures related to preparation and review of the SEFA. Effect: Adjustments of approximately $52,600 were required to properly report expenditures and adjustments of approximately $76,600 were required to properly report subrecipient expenditures on the SEFA. Recommendation: Emphasize adherence to established policies and procedures to reconcile the federal expenditures to the federal program revenue on a routine basis and formalize the independent review process for the SEFA and grant billings. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2025-004 – 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: Civic Heart had not performed a reconciliation of federal expenditures resulting in errors in reported expenditures. Additionally, subrecipient expenditures were not identified for two programs. There was no independent review of the SEFA. Recommendation: Emphasize adherence to established policies and procedures to reconcile the federal expenditures to the federal program revenue on a routine basis and formalize the independent review process for the SEFA and grant billings. Planned corrective action: Management has implemented strengthened federal reporting and reconciliation procedures to improve accuracy and oversight related to federal expenditures and SEFA preparation. Corrective actions include: 1) Implementation of a formal SEFA preparation and reconciliation process requiring reconciliation of federal expenditures to the general ledger and supporting documentation. 2) Quarterly federal expenditure reviews to identify discrepancies and improve reporting accuracy throughout the fiscal year. 3) Development of centralized federal awards tracking procedures to monitor expenditures, reimbursement activity, subrecipient activity, grant balances, and reporting requirements. 4) Independent review procedures for preparation and review of the SEFA prior to annual audit submission. 5) Strengthened coordination between accounting personnel and program leadership to improve federal reporting accuracy and monitoring of subrecipient activity. 6) Periodic internal compliance reviews to evaluate federal reporting accuracy and compliance with grant requirements. 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

Reporting

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
  • 1215566 2025-003
    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