Criteria The Uniform Guidance requires grantees to maintain its accounting records in sufficient detail to allow for the tracking of all federal funds received, as well as details on how such funds were spent. As such, management is responsible for maintaining and completing the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must accurately reflect expenditures based on qualifying costs actually incurred and must be supported by the accounting records. Condition and Context Management did not track expenses incurred under each federal award. As such, it was unable to properly report such expenses on the SEFA. Instead, the SEFA was based on cash received under each of the federal programs. Management received funds totaling $3,535,567 during the year and reported organization-wide expenses of $4,662,359. However, management was unable to provide adequate support, such as invoices, contracts, or payroll records, to support the extent to which such funds were spent on the federal program. Recommendation Management should develop a policy which requires that all direct and indirect expenses relating to federal award programs are properly coded as such and tracked in the general ledger. This coding should be reviewed by a management level employee for propriety. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: 1. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that QCHC's financial management accounting system identifies accounts for all Federal Awards, including the federal award made under the Health Center Program received, expended and the Federal programs under which they were received per 45 CFR 75.302. [Draw Down PolicytL64] 2. QCHC has established procedures to track HRSA expenses in the accounting system by revenue source fund codes by the HRSA budget name, with accounts receivable related to grants recorded when a copy of the HRSA request is received. 3. QCHC has implemented Policy 1001 -Policies and Objectives of the Purchasing section, which requires that procurements be made with complete impartiality based strictly on the merits of supplier proposals and applicable related considerations, and that all transactions be documented as required. 4. QCHC has established the Schedule of Expenditures of Federal Awards (SEFA) preparation process in accordance with the Uniform Guidance requirements, with supporting documentation retained for audit purposes. 5. QCHC has implemented a system requiring that all direct and indirect expenses relating to federal award programs are properly coded and tracked in the general ledger, with management-level review for propriety.