Finding 1240152 (2025-003)

Material Weakness Repeat Finding
Requirement
ABJL
Questioned Costs
-
Year
2025
Accepted
2026-10-07

AI Summary

  • Core Issue: Multiple deficiencies in internal controls over compliance were found, particularly in documentation and review processes for expenditures, payroll, and program income tracking.
  • Impacted Requirements: Compliance with 2 CFR 200 requires effective internal controls, including proper documentation and timely reviews, which were not consistently met.
  • Recommended Follow-Up: Strengthen internal controls by implementing documentation standards, enforcing review procedures, enhancing program income tracking, conducting periodic internal reviews, and providing compliance training.

Finding Text

#2025-003: Grant Program: Department of Health and Human Services – Assistance Listing #93.696 – Certified Community Behavioral Health Clinic Expansion – Internal Controls Over Expenditures, Financial Reporting, and Tracking of Program Income Condition: As a result of our audit procedures, we identified multiple deficiencies in internal control over compliance related primarily to documentation, review, and monitoring controls across key compliance areas. Specifically, we noted instances where evidence of review was not maintained for expenditures and payroll, lack of documented review over federal financial reports, and insufficient processes for tracking and monitoring program income. Collectively, these deficiencies indicate that internal controls were not consistently designed or operating effectively to ensure compliance with federal requirements. Certain compliance areas affected by these control deficiencies, including procurement and suspension and debarment, are addressed in a separate finding. Criteria: In accordance with 2 CFR 200 (Uniform Guidance), the Center is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. This includes maintaining adequate documentation, performing timely and evidenced reviews, and implementing monitoring controls over compliance activities. Context: The deficiencies were identified through testing across multiple compliance areas and transaction types within the major program. Exceptions included missing evidence of review on expenditures and payroll, lack of documentation supporting review of federal financial reports, and insufficient tracking and documentation of program income. These issues were not isolated, but were observed across multiple samples and processes. Cause: The deficiencies appear to be the result of insufficiently formalized policies and procedures, lack of consistent enforcement of documentation and review requirements, and ineffective monitoring of compliance-related activities. Effect: The lack of effective internal controls over compliance increases the risk that noncompliance with federal program requirements could occur and not be prevented, or detected and corrected, on a timely basis. This may result in: • Unallowable or unsupported costs being charged to federal programs • Errors or omissions in federal financial reporting • Improper monitoring or application of program income Continued noncompliance could result in increased oversight, questioned costs, or potential loss of federal funding. No known or likely questioned costs were identified as a result of the control deficiencies noted above. Recommendation: We recommend that management strengthen internal controls over compliance by: • Implementing consistent documentation standards requiring evidence of review for all key compliance activities, including expenditures, payroll, and reporting • Establishing and enforcing formal review procedures over federal financial reports • Enhancing tracking and monitoring of program income to ensure proper documentation and application • Performing periodic internal reviews to ensure compliance controls are operating effectively • Providing training to personnel responsible for compliance to reinforce documentation and review expectations Management Response: See Corrective Action Plan.

Corrective Action Plan

Finding 2025-003: Internal Controls Over Expenditures, Financial Reporting, and Program Income Corrective Action Management agrees with the recommendation. The Center will strengthen compliance monitoring procedures by requiring documented evidence of review for expenditures, payroll, federal financial reports, and other compliance activities. Written procedures will be developed to define review responsibilities and documentation requirements. The Center will establish a formal process to track, reconcile, and monitor program income and will provide training to personnel involved in federal award administration. Periodic internal compliance reviews will be performed to verify controls are functioning effectively. Implementation Timeline Policies and review procedures to be implemented during fiscal year 2026 with quarterly monitoring thereafter. Responsible Parties Chief Financial Officer, Compliance Officer, and Program Management.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240153 2025-004
    Material Weakness Repeat
  • 1240154 2025-005
    Material Weakness Repeat
  • 1240155 2025-005
    Material Weakness Repeat
  • 1240156 2025-005
    Material Weakness Repeat
  • 1240157 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $863,340
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $53,550
93.788 OPIOID STR $42,787
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $1,954