Finding Text
Internal Control over Compliance and Compliance with Cash Management Requirements Identification of the Major Federal Program: U.S. Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Grant Award Numbers under the Uniform Guidance Requirements: See Schedule of Findings and Questioned Costs for table. Criteria or Specific Requirement: In accordance with §200.305(b)(11), Federal Payment, the recipient or subrecipient must maintain advance payments of Federal funds in interest-bearing accounts unless one of the following applies: (i) the recipient or subrecipient receives less than $250,000 in Federal funding per year; (ii) The best available interest-bearing account would not reasonably be expected to earn interest in excess of $500 per year on Federal cash balances; (iii) The depository would require an average or minimum balance so high that it would not be feasible with the expected Federal and non-Federal cash resources; (iv) A foreign government or banking system prohibits or precludes interest-bearing accounts; or (v) An interest-bearing account is not readily accessible (for example, due to public or political unrest in a foreign country). Condition: During our testing of compliance, we noted that EGPAF, a HealthXP subsidiary, failed to maintain the advance payments of Federal funds under the awards NU2GGH002211, NU2GGH002301, NU2GGH002315, NU2GGH002369, NU2GGH002421, NU2GGH002425, and NU2GGH002551 in an interest-bearing account, which is noncompliant with §200.305(b)(11). Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing HealthXP’s compliance with specified cash management compliance requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: HealthXP’s management team failed to consistently maintain advance payments received from the funding agencies in an interest-bearing account as required. Effect: Failure to perform cash management procedures in accordance with HealthXP’s documented policies and relevant compliance requirements could result in non-compliance with federal statutes and contractual agreements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management ensure that cash management policies and procedures align with U.S. Government funding requirements. Views of Responsible Officials: HealthXP management agrees with the findings and recommendations set forth within and will refine its cash management policies and procedures. Refer to management’s corrective action plan for additional information.