Finding 1218154 (2024-002)

Material Weakness Repeat Finding
Requirement
CL
Questioned Costs
-
Year
2024
Accepted
2026-06-22
Audit: 404346

AI Summary

  • Core Issue: Insufficient documentation for employee activities and purchases related to federal programs.
  • Impacted Requirements: Compliance with 2 CFR section 200.430 for accurate salary and wage records.
  • Recommended Follow-Up: Maintain detailed records of employee activities and monitor compliance with the job-costing system.

Finding Text

U. S. Department of Health and Human Services 2024-002 Allowable Costs Program(s) Name of Federal Program (Assistance Listing Number) Urban Indian Health Services (93.193) Special Diabetes Program for Indians - Diabetes Prevention and Treatment Projects (93.237) Criteria - Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non-Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services for the programs identified above. Context and Condition - We selected 41 paychecks from several pay periods to test for compliance with standards in these two programs. Records for eight of the paychecks tested lacked documentation of approval of the employee’s supervisor. Cause - The Organization replaced its payroll processing servicer subsequent to 2024. Access to certain records from the prior servicer were no longer available. Personnel turnover resulting in inconsistencies in maintaining required documentation. Effect - A federal program could be charged compensation for employees who did not provide services directly attributable to the program or charged for goods/services not related to the program. Questioned Costs - No costs were questioned. Repeat finding - Yes Statistically valid - Yes Recommendation - We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job-costing system implemented. Views of responsible officials - The Organization believes the paychecks identified were approved prior to payment. We will ensure that documentation is downloaded each pay period to ensure such documentation is not lost when a change in servicer is made.

Corrective Action Plan

FINDING 2024-002 Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non-Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services. Audit Recommendation: We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job-costing system implemented. Auditee Response: Organization believes that prior leadership and lack of supervision allowed paychecks to be approved without the proper flow. FY24 Turnover was roughly 75% in leadership and 60% across the organization. Corrective Action Plan: UICSL moved away to Paycom early 2024 to better help account for Labor Allocation and Grant Codes. With Paycom, employees are automated to each program and there is a designated reporting function allowing us to review what is assigned. UICSL going into 2025 has better defined leadership and Directors for each division so there are clearly defined approvers and supervisors for each purchase and transaction – leadership turnover was high. Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director; Eva Leyer, Human Resources Manager Timeline: UICSL filled all leadership positions by mid-2025 and went through two organizational restructures, creating more mid-level management. This will help ensure compliance with FY25 Audit.

Categories

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1218152 2024-002
    Material Weakness Repeat
  • 1218153 2024-003
    Material Weakness Repeat
  • 1218155 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.193 URBAN INDIAN HEALTH SERVICES $365,227
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $356,965
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $251,867
93.479 GOOD HEALTH AND WELLNESS IN INDIAN COUNTRY $201,389
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $56,162
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $53,720
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $51,385
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $15,795
21.019 CORONAVIRUS RELIEF FUND $10,000
93.988 COOPERATIVE AGREEMENTS FOR DIABETES CONTROL PROGRAMS $5,079