Finding 1224577 (2025-002)

Material Weakness Repeat Finding
Requirement
BC
Questioned Costs
-
Year
2025
Accepted
2026-07-24

AI Summary

  • Core Issue: New England Rural Health Association lacked consistent accounting policies, leading to inaccurate financial reporting and overbilling of grants by $17,104.
  • Impacted Requirements: Failure to invoice based on actual expenditures and generate timely financial reports resulted in late submissions to the Federal Audit Clearinghouse.
  • Recommended Follow-Up: Evaluate the effectiveness of the current third-party accounting service or consider transitioning back in-house, ensuring accurate payroll allocations and timely financial reporting.

Finding Text

2025-002 Identification of the federal program: 93.241 State Rural Hospital Flexibility Program, 93.268 Immunization Cooperative Agreements, and 93.912 Rural Healthcare Services Programs Criteria: New England Rural Health Association is required to establish and implement accounting policies and procedures, including a procedure to invoice and recognize grant revenue based on actual expenditures and including a procedure to generate timely and accurate financial reports. Condition: We noted that New England Rural Health Association did not have consistent accounting policies and procedures during the year. Most notably there was a lack of financial reports for the entirety of the year. Additionally, at the beginning of the year, budgeted salaries and wages were being invoiced to grants versus actual salaries and wages. After the payroll process was updated, there were certain times the actual allocations were not correct. We also found non-payroll expenditures incorrectly charged to grants, therefore causing errors with grant invoicing and revenue recognition. The difficulties caused related to this condition have added to the multiple reasons causing the 2025 submission with the Federal Audit Clearinghouse to be late. Cause: New England Rural Health Association transitioned to using a third-party accounting service provider during 2025. New England Rural Health Association did not receive any financial reports from the service provider, therefore continued to use old methods for tracking grant expenditures and invoicing grants, which were subject to many human errors. Additionally, payroll allocations used by the service provider were not checked by New England Rural Health Association. Effect: As a result, grants were overbilled by $17,104. Questioned costs: None Context: The condition was noted in all three major programs. The entirety of 2025’s grant revenue was considered, in comparison to the entirety of 2025’s grant expenditures. The sampling was a statistically valid sample. Recommendation: We recommend that New England Rural Health Association evaluate whether its current thirdparty accounting service provider can meet its needs or whether the Association needs to consider moving the accounting function back in-house or transitioning to a new third-party accounting service provider. To aid in the evaluation, we recommend considering accounting policies and procedures that include expensing actual payroll costs to grants and generating timely financial reports. We also recommend correcting the grant revenue that was recognized in excess of actual expenditures by applying the excess amounts to current invoices or returning the amounts. Views of responsible officials: New England Rural Health Association Management have implemented controls under its new Managed Service Agreement with its third-party accounting service provider that include: timely reporting, actual cost invoicing, management review and resolution of overbilled funds.

Corrective Action Plan

Finding 2025-002: Financial Reports and Recognition of Grant Revenue Plan: NERHA originally contracted with a partner to provide financial services with the understanding that there were industry-standard systems and policies in place that were sufficient to manage and account for transactions from multiple federal and state funders. The true magnitude of the gap between the financial services provider’s financial policies and controls and NEHRA’s complex funding streams only became apparent during this audit period. The lack of financial reporting and the errors in grant invoicing (budgeted vs. actual allocations) stemmed from the number of transitions in accounting software systems and payroll systems during this period in the process of remedying the previous year’s findings and the third-party accounting provider's inability to deliver monthly financial packages during this period due to the requirement for reconciliation and adjustments to opening balances and deferred program accounts. To remediate this, management has implemented the following controls under the new Managed Service Agreement: • Timely Reporting: Once the Audit adjusting journal entries have been completed in the accounting software, GAAP-compliant monthly financial reports will be run within 15 days of month-end close process for management and board review. • Actual Cost Invoicing: Management will discontinue tracking grant expenditures using historical spreadsheet methods vulnerable to human error. Payroll and non-payroll allocations are now integrated into the accounting software and the General Ledger expenditures will be used for payroll expenses, ensuring grant invoicing is driven strictly by actual, documented expenditures rather than budgeted amounts. • Management Review: The COO will perform a monthly reconciliation of actual payroll logs against general ledger allocations prior to grant reimbursement submissions and double-verify that payroll logs match planned and worked hours. • Resolution of Overbilled Funds: Regarding the $17,104 in overbilled grant revenue, management is actively coordinating with the respective pass-through and federal granting agencies to either apply these excess amounts as a credit against current invoices or return the funds directly. Expected Completion Date: December 2026 Contacts: Ann Marie Day, Chief Operating Officer, and Andy Lowe, Executive Director New England Rural Health Association 207-228-5966 amday@newenglandrha.org andy@newenglandrha.org

Categories

Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 1224570 2025-002
    Material Weakness Repeat
  • 1224571 2025-002
    Material Weakness Repeat
  • 1224572 2025-002
    Material Weakness Repeat
  • 1224573 2025-002
    Material Weakness Repeat
  • 1224574 2025-002
    Material Weakness Repeat
  • 1224575 2025-002
    Material Weakness Repeat
  • 1224576 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $1.65M
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $95,135
66.814 BROWNFIELDS TRAINING, RESEARCH, AND TECHNICAL ASSISTANCE GRANTS AND COOPERATIVE AGREEMENTS $62,072
66.309 SURVEYS, STUDIES, INVESTIGATIONS, TRAINING AND SPECIAL PURPOSE ACTIVITIES RELATING TO ENVIRONMENTAL JUSTICE $49,591
93.155 RURAL HEALTH RESEARCH CENTERS $44,323
93.135 CENTERS FOR RESEARCH AND DEMONSTRATION FOR HEALTH PROMOTION AND DISEASE PREVENTION $25,124
93.241 STATE RURAL HOSPITAL FLEXIBILITY PROGRAM $17,508
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $15,290
93.211 TELEHEALTH PROGRAMS $3,750
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $3,138
93.913 GRANTS TO STATES FOR OPERATION OF STATE OFFICES OF RURAL HEALTH $1,500