Finding 398453 (2023-001)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-05-24

AI Summary

  • Core Issue: Internal controls for reviewing FEMA expenditures were not consistently documented, risking unallowable expenses.
  • Impacted Requirements: Compliance with Title 2, Part 200.303 on maintaining effective internal controls over Federal awards.
  • Recommended Follow-Up: Management should enhance documentation practices for the review and approval of FEMA expenses to ensure compliance.

Finding Text

Federal Program: 97.036 COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 – Internal controls. 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 the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenditures during the fiscal year for compliance with activities allowed or Unallowed, allowable Costs/Cost principles. However, management did not consistently maintain evidence of the control being performed. Context: We selected 40 expenditures for testing totaling $62,863. Of the 40 expenditures, 4 expenditures totaling $28,240 did not have evidence of review and approval. Total FEMA expenditures reported on schedule of expenditures of federal awards are $1,675,897 for the year ended August 31, 2023. Effect: Unallowable expenses could be charged to the FEMA program. Cause: Management’s internal control over the review and approval FEMA expenses for compliance with activities allowed or unallowed, allowable Costs/Cost principles requirements was not consistently documented. Identification as a repeat finding, if applicable: Not Applicable. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses to ensure documentation is retained to evidence the review and approval to support allowability of expenses. Views of responsible officials and planned corrective actions: Management agrees with the finding and will develop a plan to correct the finding.

Corrective Action Plan

Federal Agencies: U.S. Department of Homeland Security Assistance Listing No.: 97.036 COVID-19 Disaster Grants – Public Assistance Award Period of Performance: March 25, 2020 to July 01, 2022 Corrective Action Planned: Management agrees that evidence of our internal determination that certain expenses incurred for the Medline Spot Buy program was not fully documented. The Medline Spot Buy program was used as a guarantee of delivery of Personal Protection Equipment (PPE) which was in short supply during the initial stages of the Covid pandemic. These purchases were subsequently charged to the FEMA COVID grant, reviewed, and properly reimbursed to Driscoll through that grant by FEMA. Although evidence of review was not retained for the purchases through this program, management believes that adequate review was conducted in the decision to charge these costs to the grant. As it relates to the Medline Spot Buy program, Driscoll Children’s Hospital took part in the program to ensure that the Hospital was adequately stocked with necessary PPE during the COVID pandemic. This program allowed for rapid purchasing and delivery of PPE. Orders were submitted for the program by uploading a spreadsheet to Medline. This ordering process resulted in these purchases bypassing the normal purchase order approval structure. These expenses were correctly charged to the FEMA grant and their appropriateness is not in question. We have reviewed our processes related to the retention of evidence of expense review to improve audit evidence should this program ever be awarded in future periods. We will keep minutes of meetings documenting committee approval for these invoices and/or other documentation that clearly shows our internal review and decision tree. Responsible party: Steve King, CFO Implementation Date: Procedures were reviewed along with the finalization of the FY23 Uniform Guidance audit in May 2024.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 398454 2023-001
    Material Weakness
  • 398455 2023-001
    Material Weakness
  • 974895 2023-001
    Material Weakness
  • 974896 2023-001
    Material Weakness
  • 974897 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $870,112
93.268 Immunization Cooperative Agreements $338,670
20.600 State and Community Highway Safety $148,969
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $75,257
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $24,213
93.393 Cancer Cause and Prevention Research $6,000
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $2,555
93.399 Cancer Control $1,687