Finding 44082 (2022-004)

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Requirement
L
Questioned Costs
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Year
2022
Accepted
2023-06-29
Audit: 50495
Organization: Integral Global Health, Inc. (GA)
Auditor: Grace CPAS LLC

AI Summary

  • Core Issue: Lack of formal written policies for compliance with Uniform Guidance requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200, Subpart D and Subpart E could lead to issues with grant agreements.
  • Recommended Follow-Up: Establish and document written policies and procedures to ensure compliance with Uniform Guidance.

Finding Text

Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan

Corrective Action Plan

Finding 2022-004: Written Documentation of Uniform Guidance Policies and Procedures - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified noncompliance and strengthen our internal controls for compliance: Policy Development: We have initiated the development of comprehensive written policies and procedures that align with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. These policies will outline the necessary steps and guidelines for compliance with grant agreements and cost principles. Policy Review and Approval Process: We have established a formal process for reviewing and approving the written policies and procedures. This process includes involving relevant stakeholders, such as legal counsel, finance, program management, and other key departments, to ensure comprehensive coverage of the requirements and adequate alignment with our operations. Policy Implementation and Training: As the policies and procedures are finalized and approved, we will implement a robust communication and training program to ensure awareness and understanding of the requirements among our staff. This will include training sessions, workshops, and clear dissemination of the written policies throughout the organization. Policy Maintenance and Review: We recognize the importance of regularly maintaining and reviewing our policies and procedures to keep them up to date with any changes in the regulatory environment. We will establish a periodic review process to ensure ongoing compliance and make necessary updates as required. Documentation and Record-Keeping: As part of our enhanced internal controls, we will implement a system for 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. This will provide evidence of our adherence to the written policies and procedures. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $725,632