Finding 16541 (2022-001)

2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Costs Principles, Cash Management. Program. Provider Relief Fund; U.S. Department of Health and Human Services; CFDA Number 93.498. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (?200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (?200.318); 3) Allowability of costs charged to federal programs (?200.302 (7)); 4) Compensation (personnel and benefits policy) (?200.430 and ?200.431); and 5) Travel costs (including mileage and per diem) (?200.474). Condition. Although the Organization has processes in place to cover these areas, there are not formal written policies covering payments and allowability of costs charged to federal programs that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the Organization draft the required policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. MOKA policies related to use and oversight of all funds available to the Organization will be reviewed and appropriate details included as needed to fully meet and comply with the Section 200.511 requirements. The adjustments to MOKA?s policies will be reviewed and completed prior to 9/30/2023. MOKA?s internal policy review structure will be followed to ensure ongoing compliance with these requirements.