Finding Text
CRITERIA: Projects funded under this program are required to follow HRSA American Rescue Plan Act Emergency Action Section 106, Project Review Process, prior to submitting claims for reimbursement of costs for alteration or renovation projects. CONDITION: The Organization applied to the State Historic Preservation Office (SHPO) as required for approval of a roof restoration and emergency generator installation on the Prism Clinic structure in October 2021. The finance department drew down federal funds to reimburse costs after the project was completed, but before approval had been received from the SHPO. CAUSE and CONTEXT: The Organization had several communications with the SHPO during the course of the project regarding changes in scope and additional information requested by the SHPO. During the process, the individual managing the project went on leave and subsequently resigned from the Organization. The finance department followed procedures to draw down federal funds after costs had been incurred, but were not aware of the requirement for SHPO approval prior to submitting the claim. The lack of communication appears to be due to the unexpected leave taken by the project manager. EFFECT: The funder notified the Organization in September 2022 that the funds drawn down for the roof restoration and generator installation needed to be returned. Funds were returned to HRSA in October 2022. QUESTIONED COSTS: $50,284 in total. RECOMMENDATION: We recommend the Organization implement a more robust grant review process to ensure that personnel involved in managing grant funds and requests for reimbursement are aware of any special tests or provisions prior to submitting applications for reimbursement under federal programs. VIEWS of RESPONSIBLE OFFICIALS and PLANNED CORRECTIVE ACTIONS: We agree. CAP is implementing a more robust grant review process to ensure that all personnel involved in managing grant funds and requests for reimbursements are aware of special tests or provisions prior to submitting applications for reimbursements. This process includes circulating grant agreements and contracts to all those involved in management and reimbursement prior to the beginning of a grant as well as a multi-step reimbursement approvement process.