Finding 1236655 (2025-001)

Material Weakness Repeat Finding
Requirement
ABCF
Questioned Costs
-
Year
2025
Accepted
2026-09-25

AI Summary

  • Core Issue: The organization lacks complete and documented policies required by 2 CFR Part 200, impacting compliance with federal regulations.
  • Impacted Requirements: Key areas affected include cash management, allowable costs, procurement, and travel policies.
  • Recommended Follow-Up: Management should create, adopt, and implement all necessary policies, ensuring they are communicated and regularly reviewed for compliance.

Finding Text

Assistance Listing Number: 93.193 Name of Federal Program: Urban Indian Health Services; COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2025 – December 31, 2025 Criteria or Specific Requirement: Per 2 CFR Part 200, non-federal entities receiving federal awards must establish and maintain written policies and procedures addressing areas including, but not limited to: procurement (§200.317–§200.327); travel costs (§200.475); methods for avoiding duplication of costs (§200.403); subrecipient monitoring (§200.332); cash management and allowable costs (§200.302, §200.305). Condition: The organization has not implemented all policies and procedures required under the Uniform Guidance. Specifically, certain written policies and procedures required by 2 CFR Part 200, such as cash management, allowability of costs, equipment management, conflict of interest, procurement, travel, compensation, and fringe benefits, were either incomplete, not formally documented, or not in place during the audit period. Cause: Due to timing constraints and a small staff size, the Council has not detailed its policies to conform with the requirements of the Uniform Guidance. Effect or Potential Effect: Without documented and implemented policies and procedures, the organization increases the risk of noncompliance with federal regulations, inconsistent application of requirements, unallowable costs being charged to federal awards, and potential questioned costs or sanctions from funding agencies. Repeat Finding: Yes, this is a repeat of Finding 2024-003. Recommendation: Management should develop, formally adopt, and implement all required Uniform Guidance policies and procedures. Policies should be documented, communicated to relevant staff, and periodically reviewed to ensure ongoing compliance. Views of Responsible Officials: Management agrees with the finding and revise its policies and procedures to meet the criteria of the Uniform Guidance.

Corrective Action Plan

Management agrees with the finding. Management will spend additional time reviewing CFR Part 200 for familiarization. Policy templates will also be reviewed, and assistance will again be requested to develop/finalize the necessary policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1236654 2025-001
    Material Weakness Repeat
  • 1236656 2025-002
    Material Weakness Repeat
  • 1236657 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.193 Indian Health Service $1,270