Finding 1224506 (2021-013)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2021
Accepted
2026-07-23
Audit: 407750
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: Lack of management oversight over cash drawdown requests led to a material weakness in internal controls.
  • Impacted Requirements: Federal regulations require documentation linking cash receipts to actual, allowable costs for drawdowns.
  • Recommended Follow-Up: Implement procedures for retaining supporting documents and ensure all drawdown requests are reviewed and approved before submission.

Finding Text

Finding 2021-013: Cash Management – Lack of Management Oversight over Drawdown Requests – Material Weakness in Internal Control Over Compliance ALN 93.224 – Consolidated Health Centers; Grant Numbers H8GCS48610 and H8OCS00687; Grant Period: August 1, 2020 – July 31, 2021 CRITERIA Recipients of federal grants are required by federal regulations (Uniform Guidance, 2 CFR Part 200) to maintain documentation demonstrating that cash receipts correspond to drawdowns based on actual, allowable costs incurred. Drawdowns for Federal awards should be properly supported with relevant forms and reports to substantiate the costs incurred and evidence management review and approval. CONDITION AND CONTEXT For the year ended July 31, 2021, QCHC recorded cash receipts related to their federal awards totaling $3,535,567. However, QCHC was unable to provide evidence that these amounts represent drawdowns from the federal grants. The only available documentation substantiates the receipt of cash, without linking it to eligible grant expenditures. CAUSE There was significant turnover in the Finance department and the records to support grant drawdowns were not maintained. EFFECT OR POTENTIAL EFFECT We were unable to determine whether the cash received and recorded in total for the year were based on allowable costs incurred. As a result, there is a risk that federal funds may have been received in advance of, or in excess of, allowable expenditures. This could lead to noncompliance with federal regulations and potential misstatement of federal expenditures and the accuracy of the Schedule of Expenditures of Federal Awards. QUESTIONED COST $3,535,567. REPEAT FINDING No RECOMMENDATION We recommend that management establish procedures to ensure that documents supporting all drawdown requests are properly retained. Such requests should also be reviewed and approved prior to the request being made, with this approval documented and retained. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See the attached response and corrective action plan.

Corrective Action Plan

Criteria Recipients of federal grants are required by federal regulations (Uniform Guidance, 2 CPR Part 200) to maintain documentation demonstrating that cash receipts correspond to drawdowns based on actual, allowable costs incurred. Drawdowns for Federal awards should be properly supported with relevant forms and reports to substantiate the costs incurred and evidence management review and approval. Condition and Context For the year ended July 31, 2021, QCHC recorded cash receipts related to their federal awards totaling $3,535,567. However, QCHC was unable to provide evidence that these amounts represent drawdowns from the federal grants. The only available documentation substantiates the receipt of cash, without linking it to eligible grant expenditures. Recommendation We recommend that management establish procedures to ensure that documents supporting all drawdown requests are properly retained. Such requests should also be reviewed and approved prior to the request being made, with this approval documented and retained. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: l. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that drawdown of Federal funds must be made in accordance with the immediate needs of the award terms, to minimize time between request and expenditures, and funds will not be drawn down 5 business days prior to disbursement. 2. QCHC has established procedures requiring the preparation of a justification table of all staff members allocated to the federal grant fund, division of annual salaries by 26 pay periods per year, and preparation of SF-270 (Request for Advance or Reimbursement). 3. QCHC has established that the Chief Financial Officer is responsible for monitoring program cash flow needs and submitting drawdown requests in a timely manner to assure adequate coverage of program needs. 4. QCHC has implemented a review and approval process requiring the Chief Financial Officer and Chief Executive Officer to review, approve and execute the applicable drawdown. 5. QCHC has established that HRSA expenses are tracked 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.

Categories

Cash Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness Reporting

Other Findings in this Audit

  • 1224497 2021-009
    Material Weakness Repeat
  • 1224498 2021-009
    Material Weakness Repeat
  • 1224499 2021-010
    Material Weakness Repeat
  • 1224500 2021-010
    Material Weakness Repeat
  • 1224501 2021-011
    Material Weakness Repeat
  • 1224502 2021-011
    Material Weakness Repeat
  • 1224503 2021-012
    Material Weakness Repeat
  • 1224504 2021-012
    Material Weakness Repeat
  • 1224505 2021-013
    Material Weakness Repeat
  • 1224507 2021-014
    Material Weakness Repeat
  • 1224508 2021-014
    Material Weakness Repeat
  • 1224509 2021-015
    Material Weakness Repeat
  • 1224510 2021-015
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $3.13M