Finding 1224510 (2021-015)

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

AI Summary

  • Core Issue: Lack of management oversight led to insufficient documentation for indirect costs, resulting in a material weakness in internal controls.
  • Impacted Requirements: Failure to comply with Uniform Guidance (2 CFR Part 200) regarding documentation for federal grant costs, affecting both accuracy and allowability.
  • Recommended Follow-Up: Implement procedures to ensure all indirect costs are backed by adequate documentation and allocation methodologies as per federal regulations.

Finding Text

Finding 2021-015: Indirect Costs – Lack of Management Oversight to Ensure the Accuracy, Allowability and Proper Allocation of Indirect Costs – 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 Under the Uniform Guidance (2 CFR Part 200, Subpart E), recipients of federal awards must maintain documentation to support costs charged to federal programs, including indirect costs. The documentation should demonstrate that costs are allocable, allowable, and in accordance with the approved indirect cost rate agreement, if applicable. CONDITION AND CONTEXT QCHC was unable to provide sufficient records to substantiate costs charged to federal grants. As a result, we were unable to determine the accuracy or allowability of both direct and indirect costs recorded. Furthermore, due to this lack of support documentation, we could not verify whether indirect costs were charged, nor could we confirm that any indirect cost calculations were based on an appropriate and complete base of direct costs or were calculated properly in accordance with the negotiated indirect cost rate agreement. CAUSE There was significant turnover in the Finance department and the records to support the allocation of indirect costs was not maintained. EFFECT OR POTENTIAL EFFECT This may affect the accuracy of the Schedule of Expenditures of Federal Awards and compliance with federal requirements. QUESTIONED COST Unable to determine. REPEAT FINDING No RECOMMENDATION We recommend that management implement procedures to ensure that all indirect costs claimed under federal grants are supported by adequate documentation, including detailed allocation methodologies and supporting records, in accordance with federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION

Corrective Action Plan

Criteria Under the Uniform Guidance (2 CFR Part 200, Subpart E), recipients of federal awards must maintain documentation to support costs charged to federal programs, including indirect costs. The documentation should demonstrate that costs are allocable, allowable, and in accordance with the approved indirect cost rate agreement, if applicable. Condition and Context QCHC was unable to provide sufficient records to substantiate costs charged to federal grants. As a result, we were unable to determine the accuracy or allowability of both direct and indirect costs recorded. Furthermore, due to this lack of supporting documentation, we could not verify whether indirect costs were charged, nor could we confirm that any indirect cost calculations were based on an appropriate and complete base of direct costs or were calculated properly in accordance with the approved indirect cost rate agreement. Recommendation We recommend that management implement procedures to ensure that all indirect costs claimed under federal grants are supported by adequate documentation, including detailed allocation methodologies and supporting records, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: I. QCHC has implemented Section 600- Cost Accounting Policies of the Accounting Manual, which deals with the measurement, assignment and allocation of costs to various cost objectives. 2. QCHC has established Policy 619- Direct and Indirect Costs, which requires that costs benefiting more than one cost objective be consistently treated as indirect costs, and costs necessary for the overall operation of the organization be treated as management and general costs.3. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that expenditures of Federal award funds are monitored and allowable in accordance with the terms and conditions of the Federal award and with the federal cost principles in CFR Part 75 Subpart E. 4. QCHC has established Policy 303 - Incurred Cost, which requires that outlays or expenditures represent charges made to the project or program and may be reported on an accrual basis. 5. QCHC has implemented procedures to maintain detailed records of all direct and indirect costs charged to federal grants, including detailed allocation methodologies and supporting records, in accordance with federal regulations.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties 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
  • 1224506 2021-013
    Material Weakness Repeat
  • 1224507 2021-014
    Material Weakness Repeat
  • 1224508 2021-014
    Material Weakness Repeat
  • 1224509 2021-015
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $3.13M