Finding 1238049 (2025-001)

Material Weakness Repeat Finding
Requirement
ABCH
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 412859
Auditor: CTBK LLP

AI Summary

  • Core Issue: The Center failed to provide evidence of the Controller's review and approval of reimbursement requests before submission.
  • Impacted Requirements: This lack of oversight violates uniform guidance on internal controls over Federal awards, risking inaccuracies in reimbursement requests.
  • Recommended Follow-Up: Implement procedures for the Controller to review and approve all reimbursement requests, ensuring documentation of this process is retained.

Finding Text

2025-001: Review and Approval of Reimbursement Requests Criteria: Uniform guidance requires a recipient to establish, document, and maintain effective internal control over a Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal regulations and the terms and conditions of the Federal award. Effective internal controls over expenditures should include appropriate supervisory review and approval to provide reasonable assurance that costs charged to Federal awards are allowable, adequately supported, and in accordance with applicable requirements and award terms. Condition: During the audit, the Center was unable to provide evidence that the Controller reviewed and approved reimbursement requests prior to their submission for reimbursement. Although reimbursement requests were submitted, documentation demonstrating the required supervisory review and approval was not maintained. Context: The Controller is responsible for providing supervisory review of reimbursement requests prior to their submission. This review is an important component of the Center's internal control structure because reimbursement requests represent expenditures being submitted to the funding source for reimbursement. Documentation of the review provides evidence that expenditures were subject to appropriate oversight prior to submission. Cause: The Center did not have controls designed and implemented effectively to ensure that documentation evidencing the Controller’s review and approval of reimbursement requests was consistently completed and retained. Effect: The lack of documented supervisory review and approval increases the risk that reimbursement requests could include costs that are inaccurate, unsupported, unallowable, or otherwise not in accordance with applicable Federal requirements or the terms and conditions of the Federal award. Additionally, without evidence of review, the Center cannot demonstrate that the control was consistently performed. Recommendation: We recommend that the Center establish and implement procedures requiring the Controller to review and approve all reimbursement requests prior to submission for reimbursement. The Center should retain sufficient documentation that supports the review and approval, such as documented electronic approval or signature.

Corrective Action Plan

Audit Finding Reference: 2025-001 Corrective Action Plan: Reimbursement Request Review and Approval Documentation Finding: The Center was unable to provide documentation demonstrating that reimbursement requests submitted to federal funding agencies received supervisory review and approval by the Controller prior to submission. While reimbursement requests were reviewed, evidence of such review and approval was not consistently documented and retained. Root Cause: The review and approval process existed; however, formal documentation evidencing the Controller’s review and approval was not consistently retained with the reimbursement request records. Corrective Action: The Center has implemented enhanced procedures to ensure that all reimbursement requests submitted under federal awards receive documented supervisory review and approval prior to submission. Grant accounting staff will prepare the reimbursement request and supporting documentation and submit the complete package to the Controller for review. The Controller will review the request for accuracy, allowability, allocability, reasonableness, adequate supporting documentation, reconciliation to grant records and approved budgets, and compliance with applicable federal regulations and award requirements. Approval will be documented through electronic approval, email authorization retained with the reimbursement records, or signature and date on the reimbursement package or standardized checklist prior to submission. Preventive Measures: The Center has developed a standardized reimbursement request checklist that must be completed and retained with each reimbursement package. Grant accounting personnel will be trained on the revised documentation requirements, and the Executive Director will perform quarterly spot checks of reimbursement request files to confirm that evidence of review and approval is consistently maintained. Any exceptions identified will be addressed through corrective training and process improvements. Responsible Parties: Controller, Grant Accounting Staff, and Executive Director. Implementation Date: Effective immediately upon adoption. Evidence of Completion: Completed reimbursement request checklists, documented Controller approvals through signature, electronic approval, or retained email authorization, supporting reimbursement documentation, and quarterly monitoring documentation.

Categories

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 1238050 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 CONSOLIDATED HEALTH CENTERS (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $4.18M
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.02M
93.217 FAMILY PLANNING SERVICES $642,161
16.321 ANTITERRORISM EMERGENCY RESERVE $348,116
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $29,440