Finding 1218046 (2024-006)

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

AI Summary

  • Core Issue: Lack of internal controls over cash management processes may lead to noncompliance with federal payment timing requirements.
  • Impacted Requirements: Compliance with 2 CFR §200.305, which mandates minimizing the time between federal fund transfers and recipient disbursements.
  • Recommended Follow-Up: Implement internal controls for cash management to ensure adherence to federal regulations.

Finding Text

Material Weakness Finding No. 2024-006: Cash Management 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 2 CFR §200.305, the payment methods for Federal payments to recipients must minimize the time elapsing between the transfer of funds from the Federal agency to the recipient and the disbursement of funds by the recipient. Condition We noted that the Organization’s director of administrative operations has implemented a methodology designed to minimize the time that advance payment requests are expended; however there are no internal controls in place over this process. Cause The Organization’s policies and procedures do not require an internal review of the payment requests and the subsequent disbursements of the Federal funds to ensure compliance with 2 CFR §200.305. Effect The lack of internal controls could result in noncompliance with 2 CFR §200.305. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediately previous audit as Finding No. 2023-006. Recommendation We recommend that the Organization incorporate internal controls over cash management to ensure compliance with 2 CFR §200.305.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action While the Organization understood the prior year finding (2023-006) and current year renumbered recommendation (2024-006), the Organization notes the corrective actions that have been implemented, The Organization notes the following existing internal control practices, as it relates to cash management subsequent policy and process development and implementation, and the additional controls to be implemented: A. System, Process & Review Controls In Practice. 1. System Controls. The Organization operates in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. 2. Process & Review Controls – EHB & PMS. Cash management requests (aka federal draws) are computed by, and entered into the EHB, including the Organization’s justification of the expenditure, by the director of administrative operations, including the CEO on the approval request. The propriety of the cash draw is reviewed by the HHS assigned grants management specialist; and inquiry action, if needed, documented by e-mail from the grants management specialist; and approval documented in the EHB. Once the draw is approved, the director of administrative operations enters information into the PMS, noting that the CEO, is the authorized organization representative (AOR). The grants management specialist must then approve the draw request once more in the PMS system before a PMS representative approves the draw request. 3. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls include review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds – Additional Information and Statistics, Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). B. Internal Control Environment Policy Establishment – July 2025. In July 2025, the Organization developed the following cash management related policies and related procedures: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. C. Additional Process & Review Controls – March 2026. Beginning March 2026, for federal draws, process and review internal controls will be implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.

Categories

Cash Management Material Weakness

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
  • 1218038 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

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