Finding 372639 (2022-004)

Material Weakness Repeat Finding
Requirement
ABHL
Questioned Costs
-
Year
2022
Accepted
2024-03-06
Audit: 293716
Organization: Rimrock Foundation (MT)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: Rimrock Foundation lacks a proper internal control process for reviewing and approving expense submissions and statistical reports, risking ineligible claims.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) is not met, as there is no evidence of secondary review by someone other than the preparer.
  • Recommended Follow-Up: Implement a documented review and approval process for all reimbursement requests and statistical reports, ensuring oversight by a separate individual.

Finding Text

2022-004 – Department of Health and Human Services CFDA #93.829 Section 223 Demonstration Programs to Improve Community Health Services (CCBHC) Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Reporting Material Weakness in Internal Control over Compliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – Rimrock Foundation’s final expenditures identified as eligible and claimed under the federal program were reviewed and approved by separate individuals outside of the preparer. However, the expense submissions for reimbursement had no evidence of review and approval by a separate individual outside of the preparer. Rimrock Foundation’s statistical reports submitted under the federal program had no evidence of review and approval by a separate individual outside of the preparer. Cause – Rimrock Foundation has multiple individuals identifying and compiling eligible costs and statistics, however, Rimrock Foundation did not have an internal control process in place to ensure evidence of a secondary review and approval of eligible expenditures and statistical data that were summarized from the underlying supporting spreadsheets to the final expenditure listing and the final statistical reports. The final expenditure listing was used to claim allowable costs under the federal program. The review and approval of the final expenditure listing and the statistical reports submitted to the Substance Abuse and Mental Health Services Administration was not performed by someone other than the preparer of the report. Effect – Without a secondary review and approval, there is a possibility that ineligible expenditures may be claimed under the program and the reports of statistical data may not be accurately completed. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 60 expenditures was selected, from reports submitted to the Substance Abuse and Mental Health Services Administration, for testing of payroll, supplies, and equipment for activities allowed and unallowed and allowable costs/cost principles. The 20 statistical reports and forms submitted to the Substance Abuse and Mental Health Services Administration were all tested for internal controls and compliance. Repeat Finding from Prior Year – Yes. Recommendation – While we recognize that this condition is not unusual for an organization with limited staffing, it is important that Rimrock Foundation is aware of this condition for financial reporting purposes. Management and the board of directors should continually be aware of the financial accounting and reporting of Rimrock Foundation and any changes in the accounting and reporting requirements. We recommend a review and approval process which is documented in writing, by someone other than the preparer, of any reimbursement requests or any statistical reports submitted to the Substance Abuse and Mental Health Services Administration. Views of Responsible Officials – Management agrees with the finding.

Corrective Action Plan

2022-004 - Year Ended December 31, 2022 Department of Health and Human Services CFDA #93.829 Section 223 Demonstration Programs to Improve Community Health Services (CCBHC) Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Reporting Material Weakness in Internal Control over Compliance Finding Summa,y: - Rimrock Foundation's final expenditures identified as eligible and claimed under the federal program were reviewed and approved by separate individuals outside of the preparer. However, the reports submitted for reimbursement had no evidence of review and approval by a separate individual outside of the preparer. Rimrock Foundation's statistical reports submitted under the federal program also had no evidence of review and approval by a separate individual outside of the preparer. Responsible Individuals: Jeffrey Keller, CEO and Shirley Ehlang, Lead Financial Accountant Corrective Action Plan: Rimrock will have the statistical reports prepared by the Grant Financial Specialist and reviewed by the Lead Financial Account. The payment will be requested by the Lead Financial Accountant and the CFO or CEO will review the entire packet of documentation. Completion Date: December 2022

Categories

Allowable Costs / Cost Principles Cash Management Eligibility Material Weakness Period of Performance Reporting Equipment & Real Property Management

Other Findings in this Audit

  • 372640 2022-005
    Material Weakness Repeat
  • 949081 2022-004
    Material Weakness Repeat
  • 949082 2022-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.829 Section 223 Demonstration Programs to Improve Community Health Services (ccbhc) $1.54M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $469,880
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $108,276
16.838 Comprehensive Opioid, Stimulant, and Substance Abuse Site-Based Program (cossap) $104,822
93.788 Montana State Opioid Response - Sor II $36,762