Finding 2023-002 – Equipment and Real Property Management (Compliance; Internal
Controls Over Compliance)
Significant Deficiency
Criteria:
In accordance with FAR Contract Clause 52.245-1 "Government Property" the Contractor shall
establish and maintain written procedures for the maintenance, repair, protection and
preservation, control of, and accountability for Government property, consistent with the
provisions of DHHS Publication (OS) 686, entitled "Contractor's Guide for Control of Government
Property (1990)."
Condition:
During our review of the Coalition's internal controls over compliance related to the Title V major
program, we noted that the Coalition does not have an adequate system of controls established
to identify, mark, record, or maintain equipment that has been purchased with federal funds. In
addition, no annual physical inventory of the Title V equipment is being performed.
Questioned Costs:
None
Responsible Officials: Carlett Gregory CFO, Elizabeth Clifford Facilities Manager, Finance Department, Chantel Mosely Data Analyst.
• In conjunction with our IT provider, NUIHC maintains an equipment list of computer equipment. NUIHC also updates the clinic inventory for our two clinics on a quarterly basis. Other equipment is maintained using the depreciation list as well as other equipment that does not meet the fixed asset criteria. The inventory identification is in process and NUIHC will update comprehensive written procedures for the maintenance, repair, protection, preservation, control of, and accountability for equipment purchased with federal funds.
• Identification and Marking of Equipment:
• We have continued to implement a system to properly identify and mark all equipment purchased with federal funds. This will include labeling each piece of equipment with a unique identifier and clearly indicating its association with the Title V program. This is currently in process.
• Annual Physical Inventory:
• We will update our procedure to conduct an annual physical inventory of all equipment purchased with federal funds. This inventory will be maintained with finance, HR, facilities and our IT vendor, and any discrepancies will be investigated and resolved promptly.
• Training, Education and Timing:
• All staff involved in equipment management will receive training on the updated procedures. This training will ensure that staff are fully aware of their responsibilities and the procedures for managing equipment in 45 days.