Finding 35381 (2022-001)

Significant Deficiency
Requirement
BC
Questioned Costs
$1
Year
2022
Accepted
2023-09-26
Audit: 28427
Organization: Hawaii Public Health Institute (HI)

AI Summary

  • Core Issue: Indirect costs claimed for reimbursement exceeded the allowable rate under the contract.
  • Impacted Requirements: Violations of 2 CFR 200.305(b)(4) and 2 CFR 200.414(f) regarding reimbursement and cost charging.
  • Recommended Follow-Up: Update billing documentation and ensure reviews are conducted by knowledgeable personnel with supporting documentation.

Finding Text

Immunization Cooperative Agreements Assistance Listing No. 93.268 Reference Number ? Item No. 2022-001 Criteria ? Per the Code of Federal Regulations (CFR), 2 CFR200.305(b)(4), after a Federal awarding agency or pass-through entity advances cash payments to a non-Federal entity to cover its initial disbursement needs, the pass through-entity must reimburse the non-Federal entity for its actual cash disbursements. Also, per 2 CFR 200.414(f), costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. Statement of Condition ? Instances where noted were indirect costs requested for reimbursement exceeded indirect cost rate allowed under the contract. Questioned Costs ? Questioned costs for excess indirect costs billed approximated $77,800. Cause and Effect ? Due to a change in personnel during the year, certain indirect costs were requested for reimbursement under the indirect cost rate and again as indirect costs for specific expenses. Additional amounts requested for reimbursement in excess of the indirect cost rate allowed under the contract were $28,600 for Assistance Listing Nos. 93.391. Recommendation ? Documentation for the processes of the preparation and review of program billings should be updated and provided to all personnel responsible for billing granting agencies. The review of billings should be performed by individuals with direct knowledge of requirements of the grants and should include any supporting documentation used and/or calculations performed.

Corrective Action Plan

1. Excess indirect cost billing Three contracts identified with excess indirect cost billing will be corrected on the next invoice and prior to contract ending date. Assistance Listing (AL) No. 93.268 or 2103 CBO Contract and No. 93.391 or 2103 Health Equity Contract are ending by November 2023 and May 2024 respectively. Hawaii Public Health Institute (HIPHI) will submit up to date billing with corrections. As recommended by the auditors, the HIPHI team will 1) create a written procedure that describes in detail the process to prepare and review program billings, and 2) implement guidelines on how to record indirect costs. For all federally awarded programs, the Director of Finance and Operations and the program's lead manager, with direct knowledge of the requirements for the grants, will review the billing prior to submission to the funder. The Finance and Accounting Manager and/or other trained Finance and Operations staff will prepare the billings, provide financial reports as requested, and include any supporting documentation used, for the reviewers.

Categories

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

Other Findings in this Audit

  • 35382 2022-001
    Significant Deficiency
  • 611823 2022-001
    Significant Deficiency
  • 611824 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.268 Immunization Cooperative Agreements $5.48M
14.218 Community Development Block Grants/entitlement Grants $563,272
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $351,217
93.387 National and State Tobacco Control Program (b) $169,207
93.011 National Organizations of State and Local Officials $132,644
93.276 Drug-Free Communities Support Program Grants $123,192
93.426 The National Cardiovascular Health Program $115,950
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $114,341
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $96,476
10.522 Food and Agriculture Service Learning Program $89,598
93.516 Affordable Care Act (aca) Public Health Training Centers Program $83,298
93.495 Community Health Workers for Public Health Response and Resilient $57,850
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $51,883
93.322 Csels Partnership: Strengthening Public Health Laboratories $14,935
10.177 Regional Food System Partnerships (b) $7,356