Finding 1221470 (2023-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2026-06-30
Audit: 405741
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to the application of the de minimis indirect cost rate.
  • Impacted Requirements: The organization failed to document independent reviews of the cost rate application, risking noncompliance with federal cost principles.
  • Recommended Follow-Up: Implement a process requiring two individuals to review and document the application of the de minimis indirect cost rate.

Finding Text

Federal Program Information Federal Agency: U.S. Department of Health and Human Services Award Name: COVID-19 Medical Assistance Program Assistance Listing Number(s): 93.778 Award Year: 2023 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for establishing the appropriate modified total direct cost base and applying the de minimis indirect cost rate appropriately. Condition and Context There is no documented review of the application of the de minimis indirect cost rate by someone independent of the calculation process. Cause The Organization did not have adequate controls in place to ensure proper application of the de minimis indirect cost rate to the appropriate modified total direct cost base. Effect or Potential Effect There is a risk that the de minimis indirect cost rate may be applied in a manner that does not comply with applicable cost principles, potentially resulting in unallowable costs. No questioned costs are reported as this is an internal control over compliance finding. Recommendation The Organization should address the weakness in internal controls noted above by requiring two individuals to be involved in the application of the de minimis indirect cost rate, and that the review be documented. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Planned Corrective Action: GSIL will continue to strive to maintain adequate staffing levels within the Finance Department to ensure work is completed timely and to maintain documented separation of duties. A Controller position was added and filled recently to add depth to the department and help with these efforts. Additionally, vacant positions have included extensive internal and external recruiting efforts and have also recently been filled. Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Jill Bille, CFO

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1221469 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 GRANTS TO STATES FOR MEDICAID $4.27M
93.369 ACL INDEPENDENT LIVING STATE GRANTS $183,616
96.008 SOCIAL SECURITY - WORK INCENTIVES PLANNING AND ASSISTANCE PROGRAM $86,623
93.432 ACL CENTERS FOR INDEPENDENT LIVING $61,832