Finding Text
2024–003 [2023-003]—Late Reporting Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health & Human Services AL #: 93.479 Award #: 5 NU58DP006727-03-00 Award Period: 9/30/2019 to 9/29/2024 Estimated Questioned Costs: N/A Compliance Requirement: Reporting Statement of Condition During our testing of grant reporting requirements, we noted that AAIHB did not consistently submit required reports in accordance with grant requirements. Specifically, the required narrative progress report for Assistance Listing 93.479 was submitted after the required due date. In addition, one Federal Financial Report (FFR) for Assistance Listing 93.479 could not be reconciled to the supporting documentation maintained by the AAIHB. The submitted FFR reported expenditures that exceeded the available supporting reports by $58,895. Based on discussions with management, the FFR was updated during the review process to include additional expenditures, for subrecipient invoices submitted late, applicable to the reporting period; however, revised supporting documentation reconciling the submitted FFR to the accounting records was not retained. Criteria Uniform Guidance requires that AAIHB complete the required Federal Financial Reports to report cumulative expenses incurred under each grant number and required narrative Performance Reports. These reports must be submitted no later than the required due date after the end of reporting period. Financial reports should be tie to the supporting documentation. Effect AAIHB is not in compliance with federal award requirements and could jeopardize future federal funding. Cause Regarding the FFR variance, AAIHB conducted multiple reviews and revisions during the preparation and finalization of the FFR to ensure all grant expenditures were accurately recorded and reflected in the report. As a result of these revisions, supporting documentation used to reconcile and substantiate certain reported amounts was not adequately retained. The FY24 program narrative report was submitted after the required due date due to overlapping grant management responsibilities and an administrative oversight during the reporting period. The reporting requirement was inadvertently missed resulting in late submission of the program narrative. Recommendation Management should implement procedures to ensure that all required programmatic and financial reports are prepared, reviewed, and submitted by the applicable grant deadlines. In addition, management should establish procedures requiring that all Federal Financial Reports be fully supported by documentation retained at the time of submission. If revisions are made to an FFR during the review process, AAIHB should retain updated supporting schedules that reconcile the final reported expenditures to the underlying accounting records. These procedures will help ensure the completeness, accuracy, and timely submission of required grant reports and provide a clear audit trail supporting amounts reported to the grantor. View of Responsible Officials and Corrective Action Plan The AAIHB missed the reporting deadline for the program narrative reports and did not retain the final accounting support for the FFR. The AAIHB will review and revise its internal processes to ensure future program narrative reports are completed and filed in a timely manner and that accounting records to support final numbers are retained. Corrective Action Plan Timeline Corrective action plan timeline is to submit FY 2025 and FY 2026 program reports on time and retain financial support. Designation of Employee Position Responsible for Meeting Deadline Program Managers/Directors, Accounting Manager, and Grants & Contracts Specialist