Finding Text
2023-007 — Allowable Costs
Federal/state program information:
Funding agency: U.S. Department of Health and Human Services
Title: Indian Self-Determination
ALN: 93.441
Award period: 10/1/2022 – 9/30/2023
Criteria: CBNHC was awarded funding under its Master Contract and AFA under the State and Local Fiscal Recovery Funds (SLFRF). One allowable use of funds under the SLFRF Final Rule is for premium pay to essential workers. Premium pay is designed to compensate workers that, by virtue of their employment, were forced to take on additional burdens and make great personal sacrifices as a result of the COVID–19 pandemic. The SLFRF Final Rule defines eligible workers as ‘‘those workers needed to maintain continuity of operations of essential critical infrastructure sectors and additional sectors as each government may designate as critical to protect the health and wellbeing of residents”.
Condition: In November 2022, all employees and Board members of CBNHC received premium pay based on months of service during fiscal year 2022. However, Board members do not appear to meet the definition of an “essential worker” as defined under the SLFRF Final Rule.
Context: N/A
Questioned Costs: $10,416.
Cause: CBNHC Board of Directors approved premium pay to all employees, IPA/MOA contractor employees, and Board members regardless of whether each position was needed to maintain continuity of operations.
Effect: CBNHC is not in compliance with the SLFRF Final Rule related to this funding under the Indian Self-Determination program.
Auditor’s Recommendations: CBNHC should evaluate the SLFRF Final Rule and determine whether Board members meet the definition of an “essential worker”. CBNHC should consider requesting reimbursement of these funds from Board members if it is determined that Board members do not meet the definition of an “essential worker” under the SLFRF Final Rule.
Management’s Response: CBNHC acknowledges that its Board members did not meet the definition of an “essential worker” and therefore, is not in compliance with the SLFRF Final Rule related to the relief funding under the Indian Self-Determination program.