Finding Text
Assistance Listing, Federal Agency, and Program Name - 93.224, U.S. Department of Health and Human Services, Health Center Program, COVID-19 Health Center Program; 93.527, U.S. Department of Health and Human Services, COVID-19 Grants to New and Expanded Services Under the Health Center Program Federal Award Identification Number and Year - H80CS24134, 2020; H8FCS40356, 2021; H8GCS48255, 2022 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, where those records reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities. Condition - Due to a lack of effectively designed and implemented controls to ensure compliance with allowable cost principles, management requested reimbursement based upon employment contract agreements rather than actual payroll costs incurred for the individuals working under the grant. Questioned Costs - $192,677 If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - Questioned costs represent payroll costs reimbursed by HRSA which were not supported by payroll records reflecting costs incurred during the period under audit. Context - During our understanding of management’s processes and controls over grant related expenditures, we noted the absence of formal, documented review procedures to ensure costs charged to the grant were allowable and in compliance with applicable cost principles. Additionally, in reviewing the linkage between cash drawdowns and underlying federal expenditures (as noted in 2023 005), we determined that reimbursement requests for grant H80CS24134 were based on employment agreements for 10 of 14 individuals, rather than actual payroll costs supported by payroll records for expenses incurred during the grant period. Cause and Effect - Inadequately designed and implemented internal controls over payroll transactions resulted in material noncompliance with applicable cost principles. As a result, payroll related drawdowns for the referenced grant exceeded actual payroll costs incurred by approximately $193,000. The SEFA has since been adjusted to reflect allowable payroll and non payroll federal expenditures incurred during the fiscal period. Recommendation - We recommend the Organization implement controls, including levels of review, to ensure all costs conform with cost principles under 2 CFR 200, Subpart E. Views of Responsible Officials and Planned Corrective Actions - The Organization will implement controls, including levels of review, to ensure compliance with allowable cost principles.