Finding 400189 (2023-003)

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Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-06-06

AI Summary

  • Core Issue: The Institute failed to keep necessary supporting documents for 2 out of 4 data elements in performance reports related to the Opioid State Targeted Response grant.
  • Impacted Requirements: This violates §200.334 of the Uniform Guidance, which mandates retaining records for three years after the final expenditure report.
  • Recommended Follow-Up: Develop and implement policies to ensure proper documentation and retention of records supporting performance report data.

Finding Text

2023-003 – REPORTNG Federal Program: Opioid State Targeted Response Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.788 Grant Award Number and Year: #20-10328, 9/30/2020 – 9/29/2022; and #CA23MAT005. 9/30/2022 – 6/30/2024 Criteria: §200.334 of the Uniform Guidance states that "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report." Condition: It was noted during testing of the reporting requirements of this award, that the Institute could not locate supporting documents for 2 of 4 data elements selected for testing from related performance reports. These were data elements related to the results of programming, rather than financial data. Questioned Costs: No questioned costs. Cause: The Institute does not appear to have policies and procedures in place that require personnel to retain and organize documents and records collected to prepare performance reports. Effect: There is a risk that if the pass-through entity or federal agency were to request access to supporting records, the Institute would not be able to produce the requested documentation, which may jeopardize continued funding from those sources. Recommendation: We recommend that the Institute develop policies that require personnel to compile records that support data communicated to granting agencies in performance reports, and retain this documentation in accordance with Uniform Guidance record retention guidelines. Organization’s Corrective Action Plan: Refer to Organization’s Corrective Action Plan below.

Corrective Action Plan

A. Contact Person: Victor Kogler, vkogler@cibhs.org B. Corrective Action Planned: 1. Quarterly report data collected and maintained by CIBHS, for example website statistics, number of grantee technical assistance sessions, session content and number of attendees. Will be compiled by the YOR California Senior Project Coordinator, a CIBHS employee. These records will be converted to PDF, printed and archived in a file cabinet at our offices at 1760 Creekside Oaks Dr., Ste. 175, Sacramento, CA 95833. The PDF files will also be stored in a dedicated folder on the project SharePoint site. 2. Quarterly report data collected and maintained by AHP, for example Learning Collaborative attendees; training webinar attendees; number of grantee newsletters produced and distributed; and grantee activities and caseloads will be sent in PDF format to the YOR California Senior Project Coordinator at CIBHS. These records will be printed and archived in a file cabinet at our offices at 1760 Creekside Oaks Dr., Ste. 175, Sacramento, CA 95833. The PDF files will also be stored in a dedicated folder on the project SharePoint site. 3. A provision will be added to CIBHS’s contract with AHP to make the submission of data supporting the quarterly report a contractual obligation. C. Anticipated Completion Date: 6/30/2024

Categories

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.788 Opioid Str $7.03M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $1.82M