Finding 1218038 (2024-005)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2026-06-20
Audit: 404207
Organization: Papa Ola Lokahi (HI)
Auditor: KKDLY LLC

AI Summary

  • Core Issue: The Organization failed to consistently retain necessary documentation to prove contractor performance as required by federal guidelines.
  • Impacted Requirements: This finding violates the Uniform Guidance, which mandates retaining records for three years after the final expenditure report.
  • Recommended Follow-Up: Update and enforce policies to ensure proper documentation is collected and maintained for contractor services.

Finding Text

Material Weakness Finding No. 2024-005: Document Retention U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, of the Uniform Guidance, §200.334, “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…” Condition We noted that the Organization did not consistently retain documentation substantiating contractor performance of services was in accordance with the terms and conditions of the contract. Cause The Organization’s policies and procedures do not include specific requirements to ensure that pertinent supporting documents are obtained and retained to evidence contractor performance of services pursuant to Federal requirements. Effect The lack of supporting documents for contractor expenditures as stipulated by Uniform Guidance could result in noncompliance of Federal record retention polices by the Organization. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediately previous audit as Finding No. 2023-005. Recommendation We recommend that the Organization incorporate and adhere to policies and procedures to ensure the maintenance of adequate documentation to support contractor performance of services pursuant to contract terms.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…”, and recommendation made. The Organization further refers to the corrective action plan of Finding No. 2024-002: Subrecipient Monitoring, which describes the Organization’s implemented changes re: Subrecipient Monitoring and Management, Retroactive Subrecipient Portfolio Risk Assessment and Correction(s), and Subrecipient Policies and Procedures. Contractor Performance Collection and Substantiation – November 2024 The Organization has incorporated specific review procedures to ensure the timely collection and substantiation of contractor performance deliverables (e.g., products, goods, services, activities, reports), consistent with the terms and conditions of the contract. The current practices of the Organization, from the above date, to the present period of the report dated June 17, 2026, is consistent with such developed procedures.

Categories

Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1218007 2024-002
    Material Weakness Repeat
  • 1218008 2024-002
    Material Weakness Repeat
  • 1218009 2024-002
    Material Weakness Repeat
  • 1218010 2024-002
    Material Weakness Repeat
  • 1218011 2024-002
    Material Weakness Repeat
  • 1218012 2024-002
    Material Weakness Repeat
  • 1218013 2024-002
    Material Weakness Repeat
  • 1218014 2024-002
    Material Weakness Repeat
  • 1218015 2024-003
    Material Weakness Repeat
  • 1218016 2024-003
    Material Weakness Repeat
  • 1218017 2024-003
    Material Weakness Repeat
  • 1218018 2024-003
    Material Weakness Repeat
  • 1218019 2024-003
    Material Weakness Repeat
  • 1218020 2024-003
    Material Weakness Repeat
  • 1218021 2024-003
    Material Weakness Repeat
  • 1218022 2024-003
    Material Weakness Repeat
  • 1218023 2024-004
    Material Weakness Repeat
  • 1218024 2024-004
    Material Weakness Repeat
  • 1218025 2024-004
    Material Weakness Repeat
  • 1218026 2024-004
    Material Weakness Repeat
  • 1218027 2024-004
    Material Weakness Repeat
  • 1218028 2024-004
    Material Weakness Repeat
  • 1218029 2024-004
    Material Weakness Repeat
  • 1218030 2024-004
    Material Weakness Repeat
  • 1218031 2024-005
    Material Weakness Repeat
  • 1218032 2024-005
    Material Weakness Repeat
  • 1218033 2024-005
    Material Weakness Repeat
  • 1218034 2024-005
    Material Weakness Repeat
  • 1218035 2024-005
    Material Weakness Repeat
  • 1218036 2024-005
    Material Weakness Repeat
  • 1218037 2024-005
    Material Weakness Repeat
  • 1218039 2024-006
    Material Weakness Repeat
  • 1218040 2024-006
    Material Weakness Repeat
  • 1218041 2024-006
    Material Weakness Repeat
  • 1218042 2024-006
    Material Weakness Repeat
  • 1218043 2024-006
    Material Weakness Repeat
  • 1218044 2024-006
    Material Weakness Repeat
  • 1218045 2024-006
    Material Weakness Repeat
  • 1218046 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.24M
84.362 NATIVE HAWAIIAN EDUCATION $710,867
93.932 NATIVE HAWAIIAN HEALTH CARE SYSTEMS $281,520
93.387 NATIONAL AND STATE TOBACCO CONTROL PROGRAM $94,587
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $59,054
93.837 CARDIOVASCULAR DISEASES RESEARCH $21,218
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $20,590
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $18,362
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $15,770