Finding 405700 (2023-003)

Significant Deficiency Repeat Finding
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-07-01

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over cash management, leading to noncompliance with federal requirements.
  • Impacted Requirements: The lack of oversight and approval for reimbursement requests violates 2 CFR 200, which mandates proper internal controls for federal awards.
  • Recommended Follow-Up: Implement a robust internal control system to ensure all reimbursement requests are properly approved and documented before submission.

Finding Text

Finding 2023-003 Significant deficiency over internal controls and noncompliance for cash management compliance requirement. Federal Agency: Department of Health and Human Services Program Title: Section 223 Demonstration Programs to Improve Community Mental Health Services Assistance Listing Number: 93.829 Award Numbers: 21SM85247A; 1H79SM085247-01 Award Period: August 31, 2021 - August 30, 2022; August 31, 2022 - August 30, 2023 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires a non-federal entity to establish a system of internal controls in order to ensure compliance with compliance requirements under federal awards. Condition/Context for Evaluation During the audit, it was determined that there was no evidence of oversight and approval over the reimbursement requests related to cash management of the federal award. Cause This condition appears to be the result of the Organization not keeping records of their authorized reimbursement requests before it was submitted to the federal program. Effect or Potential Effect Without proper approval or evidence of approval, the Organization could request costs for reimbursement that are not allowed and do not comply with the criteria requirements under Uniform Guidance. Questioned Costs Not applicable. Repeat Finding Yes. 2022-002 Recommendation We recommend that the Organization development a system of internal controls that allows for proper approval and retention of the approval prior to cash draws being made. Views of Responsible Officials Management concurs with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Finding: 2023-003 - Oversight over cash management compliance requirement. Contact Person(s): Dan Gehl, CFO (dgehl@cmhshare.org) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreements. Corrective action planned: In September 2023, CLR has addressed the finding that its policies and procedures over reimbursement requests for federal funds lacked proper documentation of approvals according to the Uniform Guidance for federal grants. We have added a step in the online submission process with the Substance Abuse and Mental Health Services Agency (SAMHSA) to capture a screenshot of the reimbursement form to be approved before submission. Due to the timing of the FY 2022 Single Audit completion and the ending of the CCBHC contract, we were limited in the execution of this new procedure, however it is now part of our Single Audit accounting Policies and Procedures Manual. Anticipated completion date: Completed September 2023.

Categories

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

Other Findings in this Audit

  • 405699 2023-002
    Significant Deficiency Repeat
  • 982141 2023-002
    Significant Deficiency Repeat
  • 982142 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $1.22M
93.788 Opioid Str $223,054
93.150 Projects for Assistance in Transition From Homelessness (path) $129,614
93.958 Block Grants for Community Mental Health Services $115,059
93.959 Block Grants for Prevention and Treatment of Substance Abuse $64,285
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $63,333
14.231 Emergency Solutions Grant Program $21,918
97.024 Emergency Food and Shelter National Board Program $10,000