Finding Text
Finding 2022-004 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, H. Period of Performance and N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenses during the fiscal year for compliance with allowability, period of performance, and special tests and provisions requirements. However, the internal control did not include the following: ? A reconciliation to ensure the population subject to the internal control reconciled to the expenses claimed or to be claimed under the FEMA program. ? A review to ensure that invoices allocated between multiple project worksheets did not exceed claim in total. In addition, documentation over when the internal control was performed and by whom was not consistently maintained. Cause: Management?s internal control over the review and approval FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements was not properly designed. Effect or potential effect: Unallowable expenses could be charged to the FEMA program. Questioned costs: None. Context: Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is a partial repeat of finding 2021-004 from the prior year. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements. Views of responsible officials: Management agrees with the finding and will implement controls and documentation 1) to demonstrate when the control was performed and by whom, 2) to ensure that invoices allocated between multiple project worksheets do not exceed the claim in total, and 3) to include a reconciliation to ensure the population ties to the expenses claimed and expenses to be claimed.