Finding 22112 (2022-002)

Significant Deficiency
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-09-28

AI Summary

  • Core Issue: The Organization claimed $3,726 in expenses for testing supplies that were not related to COVID-19, violating FEMA guidelines.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and FEMA's Public Assistance Program guidance is essential for allowable expenses.
  • Recommended Follow-Up: Management should establish procedures to regularly review and understand the latest FEMA guidance and ensure accurate coding of expenses.

Finding Text

Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Disaster Grants - Public Assistance payments must be used for allowable expenses described in the grant agreement and specified in guidance issued by the U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA). Activities allowed and eligible costs have been outlines in the FEMA Public Assistance Program and Policy Guide, FP-104-009-2, April 2-18 (PAPPG) and FEMA COVID-19 Fact Sheets and Guidance. The purpose of the Public Assistance Grant Program as it relates to the COVID-19 pandemic is to provide funds for emergency protective measures ? actions taken to eliminate or lessen immediate threats to lives, public health, or safety related to the pandemic. Condition/Context: The Organization included expenses that did not meet criteria of an allowable expense as defined by the FEMA guidance. The Organization included $3,726 of testing supplies that were not related to COVID-19. This was not a statistically valid sample. Effect: The Organization claimed expenses that were not in accordance with established FEMA guidance and are therefore deemed unallowable. Cause: An error in the coding of certain testing supplies was not detected by the Organization?s internal control process. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood and that information used in accumulating allowable expenses is reviewed, with errors addressed.

Corrective Action Plan

The items in question were included on the same purchase order as other COVID-19 related supplies and were incorrectly charged to the grant. Going forward, the Organization will ensure the individuals accumulating allowable expenses ensure they understand the nature of all items being charged to ensure compliance with the program requirements.

Categories

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 22111 2022-001
    Significant Deficiency
  • 598553 2022-001
    Significant Deficiency
  • 598554 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $4.64M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.45M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $939,157
93.461 Covid-19 Claims Reimbursed for the Uninsured Program and the Covid-19 Coverage Assistance Fund $90,132
21.019 Coronavirus Relief Fund $22,435