Finding 33456 (2022-002)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 29220
Organization: Choice Regional Health Network (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance related to cash management, specifically regarding unapproved cash draws.
  • Impacted Requirements: Compliance with 2 CFR 200 requires minimizing the time between federal fund transfers and disbursements.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all cash draws are approved and timely disbursements are made.

Finding Text

Material weakness in internal controls over compliance and instances of noncompliance related to cash management. Federal Agency: Department of Health and Human Services Program Title: National Organizations of State and Local Officials CFDA Number: 93.011 Award Numbers: 1 G32HS42592-01-00 Award Period: July 31, 2021 - July 31, 2023 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires the non-Federal entity to utilize a payment method to minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Condition/Context for Evaluation During testing, we noted that there was only one cash draw that occurred during the year. For the cash draw selected, there was no documentation of approval for the cash draw. The Organization drew down from a federal award without incurring sufficient expenditures towards the related award. Advance draws were not approved for under the award. Questioned Costs Not applicable. Cause The Organization?s internal controls did not ensure that the cash draws were appropriately approved, and the time elapsing between the transfer of funds from the United States Treasury and disbursement was minimized. Effect or Potential Effect The Organization did not minimize the time elapsing between the drawdown of the federal funds and disbursement, resulting in cash received in excess of expenses incurred totaling $63,591 as of February 28, 2022. Allowable expenses were incurred in the following months to cover the overdraw. Repeat Finding Not applicable. Recommendation We recommend that the Organization implement the necessary internal controls to ensure payment methods are approved and minimize the time elapsing between the transfer of funds from the United States Treasury and disbursement. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Material weakness in internal controls over compliance and instances of noncompliance related to cash management. Contact Person(s): Beth Mizushima, Chief Operating Officer, mizushimab@crhn.org; and Connie Sowa, Compliance, Governance and Contracts Officer, sowac@crhn.org. Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: We agree that the one cash draw in FY22 was made without incurring sufficient expenditures towards the related award. In FY23 we have committed additional resources and staff to review expenditures from FY22 and FY23 to ensure that all project expenditures were allowable under each grant prior to drawing revenue in FY23. Additionally, in FY23 we have established a Compliance, Governance and Contracts Officer position, which provides increased oversight, approval to support drawdowns for Federal funds and to ensure compliance, adherence to requirements and improving overall internal controls and accounting processes. Anticipated completion date: We have ensured that FY23 draws are determined by the allowable expenditures for each grant. The improved accounting processes and internal controls will occur by September 30, 2023. The accounting process for Draws is included in the Accounting Manual.

Categories

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 33457 2022-003
    Significant Deficiency
  • 33458 2022-004
    Significant Deficiency
  • 609898 2022-002
    Material Weakness
  • 609899 2022-003
    Significant Deficiency
  • 609900 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.011 National Organizations of State and Local Officials $416,881
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $246,182
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $68,245
93.322 Csels Partnership: Strengthening Public Health Laboratories $42,100