Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Special Programs for the Aging
Assistance Listing Number: 93.Aging Cluster
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Condition/Context: For 21 of the 21 cash disbursements tested, there was no indication of review and
approval over the expense by a secondary, independent individual separate from the requestor.
Criteria or specific requirement: In accordance with the Compliance Supplement, Part 6 – Internal
Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and
maintain internal control over the federal awards that provides reasonable assurance that the
nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and
the terms and conditions of the federal awards.
Cause: The Organization did not have established sufficient controls designed to ensure adequate
segregation of duties in the cash distribution process. Disbursements to US Foods were established as
an automatic debit and therefore did not have individual approvals.
Effect: The Organization was not in compliance with the Compliance Supplement related to
establishing and maintaining internal controls over federal awards.
Repeat Finding: No
Recommendation: We recommend that the Organization implement policies and procedures
surrounding the cash disbursement process that ensures all disbursements are reviewed and approved
by a second, independent individual.
Views of responsible officials: Management agrees with the audit condition.