Finding 194999 (2022-001)

Material Weakness
Requirement
ABCHL
Questioned Costs
-
Year
2022
Accepted
2023-03-20
Audit: 178651
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: Lack of independent review and approval in compliance processes for federal awards.
  • Impacted Requirements: Failure to maintain effective internal controls as required by 2CFR 200.303(a).
  • Recommended Follow-Up: Management should establish and document independent review procedures to enhance compliance controls.

Finding Text

2022-001 Department of Health and Human Services Federal Financial Assistance Listing #93.889, 22SC091990 National Bioterrorism Hospital Preparedness Program Activities Allowed and Allowable Costs, Period of Performance, Cash Management and Reporting Material Weakness in Internal Control over Compliance Criteria: 2CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. Cause: The Coalition hasn?t formally adopted and implemented updated internal control procedures since departure of the Grant Management Director. Effect: Without established controls over activities allowed and allowable costs, period of performance, cash management and reporting, there is a reasonable possibility that the Coalition would not detect noncompliance in the normal course of performing duties and correct them in a timely manner. Questioned Costs: None reported. Context: Testing was performed over the compliance requirements as follows: -Activities Allowed, Allowable Costs and Period of Performance ? A non-statistical sample of 60 nonpayroll transactions were selected for testing, accounting for approximately $379,111 of $749,012 total non-payroll costs charged to the federal award. Additionally, all Executive Director wages charged to the federal award were tested. -Cash Management ? A non-statistical sample of 13 out of 64 draw requests were selected for testing. -Reporting ? the close-out report required to be filed in the fiscal year was tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management implement procedures and control processes to incorporate and document an independent review and approval. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Finding: 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: National Bioterrorism Hospital Preparedness Program Federal Financial Assistance Listing #93.889 Compliance Requirement: Activities Allowed and Allowable Costs, Period of Performance, Cash Management and Reporting Finding Summary: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, Internal control procedures documented within Coalition?s Grant Management Policy have not been updated since departure of the Grant Management Director. Responsible Individuals: Greg Santa Maria, Executive Director Corrective Action Plan: The SDHCC has updated its invoicing process to include an internal review of all invoices prior to submission for reimbursement by the state. Per the new process, the executive director reviews, prepares and completes the initial invoicing process. Once complete, the invoice is forwarded to the SDHCC treasurer for final review and approval prior to final submission to SD DOH. The review process is formally documented by treasurer signature on face document prior to submission to DOH. Grant management policy is currently in revision. Anticipated Completion Date: For Invoicing Process, practice was changed to reflect final review by SDHCC treasurer on January 10, 2023, beginning with BP4 Invoice number 227. Projected Grant Management policy revision first draft to Board is Friday April 7, 2023.

Categories

Allowable Costs / Cost Principles Cash Management Material Weakness Period of Performance Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 195000 2022-002
    Material Weakness
  • 195001 2022-003
    Material Weakness
  • 195002 2022-004
    Material Weakness
  • 771441 2022-001
    Material Weakness
  • 771442 2022-002
    Material Weakness
  • 771443 2022-003
    Material Weakness
  • 771444 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.889 National Bioterrorism Hospital Preparedness Program $877,016