Finding 3487 (2022-003)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2023-12-05

AI Summary

  • Core Issue: High Sierra AHEC misapplied allowable indirect cost rates, leading to reimbursement requests exceeding actual indirect costs by $32,115.
  • Impacted Requirements: Internal controls over compliance were inadequate, failing to ensure that reimbursement requests aligned with actual expenditures.
  • Recommended Follow-Up: Implement a new internal control system to accurately track indirect costs and limit reimbursement requests to the lesser of allowable rates or actual costs incurred.

Finding Text

U.S. Department of Health and Human Services, Passed Through the State of Nevada Department of Health and Human Services Division of Public & Behavior Health, COVID-19 Public Health Workforce, Assistance Listing Number 93.391 Criteria: As defined in 45 CFR 75, the auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award, including all allowable indirect and fringe cost rates. Condition: High Sierra AHEC applied allowable indirect cost rate to all direct requests for reimbursement, regardless of the amount of indirect costs actually expended. Cause: Management misunderstood the application of allowable indirect cost rates, believing that all direct expenditures were applicable to the rates, even if indirect costs had not been incurred up to or in excess of the percents allowable. As a result of the misunderstanding, internal controls to prevent and detect requests for reimbursement in excess of actual expenditures were not designed. Context: As noted in finding 2022-001, misapplication of allowable indirect cost rates was pervasive across all federal grant award funding. Effect and Known Questioned Costs: Requests for reimbursement exceeded indirect costs incurred by $32,115 for this federal award program. Repeat Finding: No U.S. Department of Health and Human Services, Passed Through the State of Nevada Department of Health and Human Services Division of Public & Behavior Health, COVID-19 Public Health Workforce, Assistance Listing Number 93.391 (Continued) Recommendation: We recommend an internal control system be designed to identify indirect costs incurred and to prevent and detect requests for reimbursement to utilize the lesser the percentage of allowable direct costs expended during the period or actual indirect costs incurred when applying allowable indirect cost rates. Views of Responsible Officials and Planned Corrective Actions: We will utilize our current profit and loss by class tracking in our general ledger software to identify indirect costs incurred and ensure the requests for reimbursement to not exceed the lesser of 10 percent of direct costs expended during the period or actual indirect costs incurred.

Corrective Action Plan

In accordance with federal audit protocols, our organization underwent a rigorous evaluation administered by Jessica Sayles, CPA, representing the prestigious firm Houldsworth, Russo, and Co. for fiscal year 2021-2022. Specifically, the audit was conducted with a focus on our utilization of funds allocated under the ARP grant. This comprehensive audit revealed two distinct facets deserving of meticulous attention. Firstly, we are pleased to report that the examination of our direct expenditures under the ARP grant has yielded an impeccable record of financial stewardship. No anomalies, deficiencies, or discrepancies were identified in the management of these direct expenses. This outcome reaffirms our unwavering commitment to fiscal diligence in the administration of public funds. However, the audit did unveil an issue of significance, pertaining to our handling of indirect expenses and fringe rates. Ms. Jessica Sayles, discerned that our organization had inadvertently transgressed established regulations governing allowable indirect cost rates, particularly in relation to payroll and other miscellaneous expenses. This misapplication resulted in the disbursement of funds beyond the thresholds specified under the Uniform Guidance framework, consequently necessitating reimbursement to federal agencies. This disclosure is an acknowledgment of the audit findings and represents our steadfast commitment to forthrightness, transparency, and responsible financial management. We deeply respect the critical importance of precision and adherence to federal guidelines in matters of fiscal accountability, and we are dedicated to addressing these issues with utmost professionalism. Issue 1: Material Adjustments to the Financial Statements We acknowledge the discovery of material current and prior period adjustments necessary to ensure that our financial statements are fairly stated in accordance with generally accepted accounting principles (GAAP). We understand the importance of accurate financial reporting and have already taken steps to address this concern. Our response to this issue includes: Comprehensive Review: We have initiated a thorough review of our accounting records to identify the root causes of these material adjustments. This process includes examining internal controls and financial reporting procedures. Rectification Plan: A plan has been developed to rectify these adjustments promptly, with a focus on maintaining compliance with GAAP. This includes improved monitoring, internal auditing, and reporting protocols. Training and Development: Our finance and accounting team have undergone additional training and development to strengthen their understanding of financial reporting standards, and GAAP compliance. Issue 2: Uniform Guidance - Allowable Indirect Cost Rates We acknowledge the findings related to the misapplication of allowable indirect cost rates for payroll and other expenses. We deeply regret the misunderstanding that led to this issue and take full responsibility for it. To address this matter, we have initiated the following actions: Immediate Compliance: We have already taken steps to ensure that allowable indirect cost rates are correctly applied in accordance with Uniform Guidance. This includes a review of all grant expenditures and related indirect costs. Training and Education: We are committed to improving our management's understanding of allowable indirect cost rates. Specialized training sessions will be conducted to clarify the proper application of these rates to prevent such errors in the future. Reconciliation and Repayment: We have worked closely with federal agencies, who opted for a refundable advance, to reconcile the amounts overdrawn on federal requests for reimbursements and promptly addressed any amounts due as a result of the misapplication of indirect cost rates. We recognize the gravity of these findings and are actively working to ensure that such misapplications will not recur in the future. In tandem with this, we commit to working diligently alongside Ms. Sayles and her esteemed team to expeditiously rectify these concerns and establish a robust framework for accurate financial reporting in our future endeavors. This organization remains firmly committed to upholding the highest standards of integrity, accountability, and compliance in its financial operations. We extend our appreciation to your department for your dedication to ensuring responsible fiscal oversight and the judicious allocation of federal resources. Should you require additional information or wish to engage in a more detailed discussion of these matters, we are readily available for dialogue. Andrea L. Gregg Chief Executive Officer High Sierra AHEC 639 Isbell Road, Suite 290 Reno, NV 89509 (775) 507-4022 andrea@highsierraahec.org

Categories

Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 579929 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $388,037
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $260,649
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $101,083
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $16,138
17.285 Apprenticeship USA Grants $14,060