FAC Explorer

Finding 39689 (2022-005)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-07-10
Audit: 37825
Organization: Cook County, Illinios (IL)
Auditor: Washington Pittman & McKeever LLC

AI Summary

  • Core Issue: The Cook County Department of Public Health failed to comply with federal regulations regarding allowable costs, leading to inadequate documentation and unsupported expenditures.
  • Impacted Requirements: Compliance with 2 CFR Part 200, which mandates effective internal controls and proper documentation for federal awards.
  • Recommended Follow-up: Implement procedures to ensure all expenditures are documented, reasonable, and reviewed; conduct regular reconciliations of grant activities to confirm only allowable costs are reported.

Finding Text

Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?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 terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with federal regulations over allowable costs. CAUSE Based on discussions with management, the cause of this finding resulted from not following the established controls that ensure proper support documentation is included with the journal entry chargeback entries prepared by Finance staff to justify the charges incurred to the Grant. Additionally, the Program Lead (key personnel) assigned to the program left the organization prior to the Grant ending which affected the periodic review for allowable costs/charges. EFFECT The failure to maintain adequate supporting documentation and to ensure all expenditures are allowable, reasonable, and properly reviewed and approved resulted in the identification of questioned costs and is a violation of federal regulations. QUESTIONED COSTS We noted total potential questioned costs in the amount of $336,583. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 (Continued) CONTEXT During fiscal year 2022, we noted total program expenditures were incurred under five grant agreements (three with the Illinois Department of Public Health (IDPH) and two with the City of Chicago). For the IDPH grants, we tested 6 expenditure samples (from a population of 28), noting for two expenditures (totaling $1,618,957), adequate documentation was not initially provided to support the total amount charged to the program. As a result, DPH management subsequently provided a reconciliation of additional grant expenditures to support these charges. Upon further review, we noted that only $1,282,374 represents allowable costs that could be charged to the program, as other amounts noted were previously transferred to the grant in prior periods. The unreconciled difference of $336,583 remains unsupported and as such, represented potential questioned costs under the IDPH funded portion of the program. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH ensure adequate documentation is maintained to support charges to the federal program and comply with federal regulations. Also, procedures should be developed and implemented to ensure all expenditures are allowable, reasonable, and properly reviewed and approved prior to charging the expenditures to the federally funded program. Finally, periodic and timely reconciliation of grant activities should be performed to ensure only allowable costs are being reported under the program. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.

Corrective Action Plan

Finding #2022-005: regarding CCDPH not adequately complying with federal regulations over allowable costs. Cause: The cause of this finding resulted from not following the established controls that ensure proper support documentation is included with the journal entry chargeback entries prepared by Finance staff to justify the charges incurred to the Grant. Additionally, the Program Lead (key personnel) assigned to the program left the organization prior to the Grant ending which affected the periodic review for allowable costs/charges. Corrective Action: The CCH Director of Grant Accounting will reinforce current internal controls so that the reviewer/approver (staff who prepares the chargeback) includes proper supporting documents and attaches to the entries in the EBS Oracle System. Additionally, the CCH Director of Grant Accounting will continue to reinforce current CCH procedures and ensure Grant expenditures are periodically reviewed and checked for allowability and reasonableness (based on activities) by both the Finance and Programmatic areas. Anticipated completion of the corrective action will be December 31, 2023.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 39681 2022-001
    Significant Deficiency
  • 39682 2022-002
    Significant Deficiency
  • 39683 2022-003
    Significant Deficiency
  • 39684 2022-003
    Significant Deficiency
  • 39685 2022-007
    Significant Deficiency
  • 39686 2022-008
    Significant Deficiency
  • 39687 2022-009
    Significant Deficiency
  • 39688 2022-010
    Significant Deficiency Repeat
  • 39690 2022-006
    Significant Deficiency Repeat
  • 39691 2022-004
    Significant Deficiency
  • 616123 2022-001
    Significant Deficiency
  • 616124 2022-002
    Significant Deficiency
  • 616125 2022-003
    Significant Deficiency
  • 616126 2022-003
    Significant Deficiency
  • 616127 2022-007
    Significant Deficiency
  • 616128 2022-008
    Significant Deficiency
  • 616129 2022-009
    Significant Deficiency
  • 616130 2022-010
    Significant Deficiency Repeat
  • 616131 2022-005
    Significant Deficiency
  • 616132 2022-006
    Significant Deficiency Repeat
  • 616133 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $166.10M
93.498 Provider Relief Fund $31.16M
97.067 Homeland Security Grant Program $19.96M
95.001 High Intensity Drug Trafficking Areas Program $17.79M
14.218 Community Development Block Grants/entitlement Grants $13.52M
93.563 Child Support Enforcement $8.36M
20.205 Highway Planning and Construction $8.11M
14.239 Home Investment Partnerships Program $6.01M
93.268 Immunization Cooperative Agreements $5.31M
14.231 Emergency Solutions Grant Program $5.13M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $4.55M
21.023 Emergency Rental Assistance Program $2.50M
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $2.07M
16.575 Crime Victim Assistance $1.57M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.42M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $1.35M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $931,606
93.069 Public Health Emergency Preparedness $887,672
93.788 Opioid Str $831,960
93.959 Block Grants for Prevention and Treatment of Substance Abuse $792,572
93.136 Injury Prevention and Control Research and State and Community Based Programs $752,205
16.738 Edward Byrne Memorial Justice Assistance Grant Program $696,342
66.001 Air Pollution Control Program Support $686,074
16.543 Missing Children's Assistance $657,103
93.926 Healthy Start Initiative $642,438
16.588 Violence Against Women Formula Grants $548,463
97.042 Emergency Management Performance Grants $546,515
93.495 Community Health Workers for Public Health Response and Resilient $524,460
21.016 Equitable Sharing $522,217
21.027 Coronavirus State and Local Fiscal Recovery Funds $495,607
93.884 Grants for Primary Care Training and Enhancement $429,240
10.555 National School Lunch Program $367,132
16.034 Coronavirus Emergency Supplemental Funding Program $366,158
16.827 Justice Reinvestment Initiative $332,345
90.404 2018 Hava Election Security Grants $305,823
93.247 Advanced Nursing Education Grant Program $305,068
14.905 Lead Hazard Reduction Demonstration Grant Program $303,865
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $301,984
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $271,707
16.585 Drug Court Discretionary Grant Program $270,194
16.922 Equitable Sharing Program $257,715
16.320 Services for Trafficking Victims $248,536
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $212,094
16.582 Crime Victim Assistance/discretionary Grants $208,836
16.838 Comprehensive Opioid Abuse Site-Based Program $193,851
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $182,908
10.553 School Breakfast Program $170,457
16.825 Smart Prosecution Initiative $170,290
20.530 Public Transportation Innovation $164,297
93.226 Research on Healthcare Costs, Quality and Outcomes $143,304
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $141,026
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $134,043
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $128,386
93.586 State Court Improvement Program $121,220
16.752 Economic High-Tech and Cyber Crime Prevention $111,583
16.836 Indigent Defense $108,212
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $103,931
16.593 Residential Substance Abuse Treatment for State Prisoners $87,018
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $86,632
20.600 State and Community Highway Safety $75,060
12.617 Economic Adjustment Assistance for State Governments $63,905
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $61,381
93.855 Allergy, Immunology and Transplantation Research $57,033
93.217 Family Planning_services $56,907
93.669 Child Abuse and Neglect State Grants $55,296
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $55,000
16.021 Justice Systems Response to Families $53,487
93.253 Poison Center Support and Enhancement Grant $40,520
93.439 State Physical Activity and Nutrition (span $34,000
11.307 Economic Adjustment Assistance $33,508
16.754 Harold Rogers Prescription Drug Monitoring Program $32,962
17.285 Apprenticeship USA Grants $26,312
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $20,000
66.032 State Indoor Radon Grants $5,007
66.605 Performance Partnership Grants $1,388
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $477
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $100
93.110 Maternal and Child Health Federal Consolidated Programs $-455
16.812 Second Chance Act Reentry Initiative $-25,834
21.019 Coronavirus Relief Fund $-87,542
93.667 Social Services Block Grant $-248,432