Finding 401926 (2022-003)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2024-06-25

AI Summary

  • Core Issue: Lack of proper internal controls and segregation of duties in the billing process for the federal program.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and internal control standards, risking inaccurate billing to the federal program.
  • Recommended Follow-Up: Establish formal policies to ensure documented segregation of duties and effective cash management controls.

Finding Text

Federal Program: Section 223 Demonstration Programs to Improve Community Mental Health Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 93.829 Federal Award Number: H79SM083269 Federal Award Year: December 31, 2022 Criteria: 2 CFR 200.303 states that recipients of federal program funding must 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/Context: Evidence of proper segregation of duties or internal controls over the federal program's billing process could not be provided. Cause: The Organization's process for compiling the reimbursable expenditures and billing those amounts to the Federal awarding agency were completed by a single individual. Both this individual and the personnel that would have been responsible for reviewing and approving the amounts billed are no longer with the Organization. As such there was no evidence provided of segregation of duties or internal control over the amounts charged to the Federal program Effect: Inadequate controls over the cash management process could result in reimbursable costs billed to Federal programs that are inaccurate or unallowable. Questioned Costs: None noted Recommendation: The Organization should have formal policies that provide documentary evidence of proper segregation of duties and control structures over Federal program cash management. Views of responsible officials: Management agrees with the auditors' finding and will take action to implement controlling procedures over federal programs.

Corrective Action Plan

The Organization will implement control procedures that maintain proper segregation of duties. Expenditure amounts that are to be applied to federal awards shall be prepared the Staff Accountant and will require the formal approval from an individual in leadership (COO, Controller) prior to being recorded. The prepared file and documentation of the review and approval will be retained in a share drive for future access.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 401925 2022-002
    Significant Deficiency
  • 401927 2022-004
    Significant Deficiency
  • 978367 2022-002
    Significant Deficiency
  • 978368 2022-003
    Significant Deficiency
  • 978369 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $1.10M
93.788 Opioid Str $929,833
14.239 Home Investment Partnerships Program $600,000
14.218 Community Development Block Grants/entitlement Grants $180,800
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $146,795
21.027 Coronavirus State and Local Fiscal Recovery Funds $102,708
16.034 Coronavirus Emergency Supplemental Funding Program $69,650
93.959 Block Grants for Prevention and Treatment of Substance Abuse $52,265