FAC Explorer

Finding 498881 (2023-001)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321664
Organization: United Voices for Newcomer Rights (NM)
Auditor: Jaramillo Accounting Group LLC

AI Summary

  • Core Issue: Management is making disbursements to subrecipients without requiring invoices, leading to a significant overpayment of $27,525.
  • Impacted Requirements: This practice violates compliance areas related to Allowable Costs and Cash Management, as outlined in federal regulations.
  • Recommended Follow-Up: Implement a process to require invoices from subrecipients before disbursements to prevent future overpayments and ensure compliance.

Finding Text

2023-001 OVERPAYMENTS TO SUBRECIPIENT Federal agency: U.S. Department of Department of Health and Human Services Federal Program Title & Assistance Listing Number: Substance Abuse and Mental Health Services Projects of Regional and National Significance -93.243 Award Period: 12/31/2022 - 12/30/2024 Type of Finding: Significant Deficiency Compliance Areas: Allowable Costs, Cash Management Questioned Costs: None Condition During our testing of subrecipient disbursements, we found that management does not require invoices from subrecipients before making disbursements. Instead, they allocate a predetermined monthly amount based on prorated subaward totals, making adjustments upon receipt of invoices and again at year-end. An error in a subrecipient's invoice led to an overpayment of $27,525 and remained uncorrected during the year. As a result, UVNR over recognized federal revenue by the same amount. An audit adjustment was made to correct both federal expenditures and revenues in 2023. Criteria An improper payment, as defined in 2 CFR §200.1, is any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements. According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Specific to the Organization, federal reimbursement requests are completed monthly. Effect Overstatement of federal revenues and expenditures, respectively. The overpayment would also necessitate certain adjustments to the award amounts given to the subrecipient in the following year. Cause Management admittedly overlooked the error in the subrecipient’s submitted invoice during review.

Corrective Action Plan

Recommendation UVNR should implement procedures to ensure thorough monitoring and accurate accounting of all subrecipient expenditures. Subrecipients should be required to submit properly supported invoices with their reimbursement requests. It is also recommended that authorized grant personnel diligently review and approve these invoices to ensure that reimbursements are made only for actual expenditures. Management Response Corrective Action: 1. Meet with subrecipient to clarify compliance issues with 2023 disbursements and to discuss plans of action for 2024 through grant period end (occurred on 9/10/24). 2. Subrecipient will invoice monthly providing grant personnel with an invoice and general ledger of expenses. 3. Grant personnel will adopt a policy of reviewing subrecipient’s monthly invoices and supporting documents, including adding a requirement for grant personnel to approve and sign subrecipient invoices before drawing down from the federal award’s payment management system. 4. Signed and approved grant invoices and supporting documentation will also be shared with accounts for approval before drawing down from the federal award’s payment management system. 5. Grant personnel will meet regularly with accountants for thorough and continuous monitoring of the award, including accurate accounting of subrecipient funds Due Date of Completion: September 30, 2024 - ongoing Responsible Party(ies): Co-Executive Directors

Categories

Subrecipient Monitoring Cash Management Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1075323 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $799,006