Finding 47380 (2022-002)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-06-20

AI Summary

  • Core Issue: Inadequate review process led to $1,051 in non-program cell phone costs being charged to the COVID-19 Emergency Solutions Grant.
  • Impacted Requirements: Compliance with 2 CFR § 200.405 on allocable costs was not met, as costs were not properly assigned to the federal award.
  • Recommended Follow-Up: Implement stronger controls for reviewing and approving non-payroll expenses to ensure only relevant costs are charged to the program.

Finding Text

Item: 2022-002 Assistance Listing Number: 14.231 Programs: COVID-19 - Emergency Solutions Grant ? Homeless Street Outreach Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 154962-0 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? September 30, 2022 Compliance Requirement: Allowable Activities and Costs Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. One employee's phone bill continued to be charged to the grant after they stopped working on the program. Questioned Costs: $1,051 Context: In a population of 75 non-payroll costs charged to the program, we conducted a non-statistical sample of 40 non-payroll costs charged to the program. In our sample of 40, we noted 4 selections included an allocation of cell phone charges for an employee who did not work on the program. Additionally, we noted 1 of the same 40 selections did not have the proper review and approval before being paid. As a result of our sampling error, we reviewed all twelve cell phone charges for this employee charged to the program during the fiscal year ended September 30, 2022 and noted that cell phone charges were improperly charged to the program for the period from November 2021 through August 2022 for a total questioned costs of $1,051. This is deemed to be a material weakness in internal control over compliance. Effect: Non-payroll costs totaling $1,051 were inappropriately charged to the federal program. Cause: Southwest Behavioral Health Services, Inc. and Subsidiaries did not have adequate controls in place to properly review and approve non-payroll expenses to ensure only costs associated with employees who worked on the program were charged to the major federal program. Identification as a Repeat Finding: Not a repeat finding Recommendation: Southwest Behavioral Health Services, Inc. and Subsidiaries should implement controls to adequately review and approve non-payroll expenses to ensure only costs associated with employees who worked on the program were charged to the major federal program. Views of Responsible Officials: Management of Southwest Behavioral Health Services concurs with the finding. See Corrective Action Plan.

Corrective Action Plan

Item: 2022-002 Assistance Listing Number: 14.231 Programs: COVID-19 Emergency Solutions Grant ? Homeless Street Outreach Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 154962-0 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? September 30, 2022 Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. One employee's phone bill continued to be charged to the grant after they stopped working on the program. Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish additional policies and procedures to ensure adequate review of cell phone bills occurs and terminated and transferred employees are removed immediately. Additionally, we will implement proper review controls over the cost reimbursement reports to identify issues like these timely.

Categories

Questioned Costs Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 47381 2022-003
    Material Weakness
  • 47382 2022-004
    Material Weakness
  • 623822 2022-002
    Material Weakness
  • 623823 2022-003
    Material Weakness
  • 623824 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.241 Housing Opportunities for Persons with Aids $1.66M
14.181 Supportive Housing for Persons with Disabilities $1.04M
93.788 Opioid Str $885,133
14.231 Emergency Solutions Grant Program $439,279
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $369,002
14.157 Supportive Housing for the Elderly $280,319
93.959 Block Grants for Prevention and Treatment of Substance Abuse $157,215
93.788 State Opioid Response (sor) $138,184
14.218 Community Development Block Grants/entitlement Grants $126,963
93.276 Drug-Free Communities Support Program Grants $103,162
93.958 Block Grants for Community Mental Health Services $52,151
93.914 Hiv Emergency Relief Project Grants $18,538
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $14,020
93.778 Medical Assistance Program $600