Finding Text
Finding 2022-003 ? Internal Control Deficiency Reporting Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There are no internal controls in place to ensure that reports that are submitted are complete and accurate. The same individual that prepares the SF-425 report, is the same person that reviews and submits the reports. Cause: Controls were not designed to properly segregate duties whereby some independent of the preparer is reviewing the reports prior to submission. Effect or potential effect: Reports could reflect inaccurate information. Questioned Costs: None. Context: Because there was not appropriate segregation of duties, we could not test internal controls over Reporting. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: AdviseWell should develop and implement effective internal controls to properly segregate duties whereby some independent of the preparer is reviewing the reports prior to submission. View of Responsible Officials: Management agrees with the finding. Controls will be implemented whereby the person preparing the reports is independent of the person reviewing the reports.