Finding 499123 (2023-002)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321903
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: There were significant deficiencies in FFATA reporting, including lack of review and timely submission of subawards.
  • Impacted Requirements: Compliance with 2 CFR Section 200.303 and FFATA reporting requirements for subawards of $30,000 or more.
  • Recommended Follow-Up: Implement a review process by the CFO for FFATA reports and establish reminders to ensure timely submissions.

Finding Text

Finding 2023-002 - Reporting: Federal Funding Accountability and Transparency Act ("FFATA") – Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name(s): Health Center Program Cluster - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and COVID-19 - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and Grants for New and Expanded Services Under the Health Center Program and COVID-19 - Grants for New and Expanded Services Under the Health Center Program Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number(s) and Year(s): H8F4083 - 2021, H8000626 - 2022, H8G48366 - 2022 Criteria 1. In accordance with 2 CFR Section 200.303, Internal controls, the non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2. Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, prime recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime recipient is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition 1. During our audit, we noted there was no evidence of review and approval by someone other than the preparer of the FFATA subawards that were submitted to the FSRS. 2. During our audit, we noted the FFATA subawards were not submitted timely to the FSRS. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 4 4 4 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $6,845,844 $6,845,844 $6,845,844 $0 $0 Cause 1. There is no formal policy in place requiring the CFO (or designee) to review and approve the FFATA reports before submission to the FSRS. 2. As a result of personnel changes within the finance department, the FFATA reporting was not done timely. Effect or Potential Effect 1. The condition could result in key data elements inaccurately reported and/or not supported by the source documentation. 2. The FFATA subawards were not submitted timely to the FSRS. Questioned Costs None. Context Four exceptions from a statistically valid sample of four. Identification as Repeat Finding 1. No 2. Yes (see prior year finding number 2022-001) Recommendation 1. We recommend that all FFATA reports be reviewed and approved by the CFO or designee and evidence of approval be maintained. 2. We recommend that management create an e-mail reminder or other alert mechanism and implement controls to ensure compliance with the reporting requirements under FFATA. Views of Responsible Officials As of September 1, 2023, BCHN implemented a workflow where FFATA information will be reported to the FSRS upon receipt of the Notices of Award. In addition, as of September 9, 2024, the FFATA report will be reviewed by someone other than the preparer prior to submission and evidence of the approval maintained.

Categories

Subrecipient Monitoring Reporting HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 499114 2023-002
    Significant Deficiency Repeat
  • 499115 2023-003
    Significant Deficiency
  • 499116 2023-004
    Significant Deficiency
  • 499117 2023-002
    Significant Deficiency Repeat
  • 499118 2023-003
    Significant Deficiency
  • 499119 2023-004
    Significant Deficiency
  • 499120 2023-002
    Significant Deficiency Repeat
  • 499121 2023-003
    Significant Deficiency
  • 499122 2023-004
    Significant Deficiency
  • 499124 2023-003
    Significant Deficiency
  • 499125 2023-004
    Significant Deficiency
  • 1075556 2023-002
    Significant Deficiency Repeat
  • 1075557 2023-003
    Significant Deficiency
  • 1075558 2023-004
    Significant Deficiency
  • 1075559 2023-002
    Significant Deficiency Repeat
  • 1075560 2023-003
    Significant Deficiency
  • 1075561 2023-004
    Significant Deficiency
  • 1075562 2023-002
    Significant Deficiency Repeat
  • 1075563 2023-003
    Significant Deficiency
  • 1075564 2023-004
    Significant Deficiency
  • 1075565 2023-002
    Significant Deficiency Repeat
  • 1075566 2023-003
    Significant Deficiency
  • 1075567 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $6.63M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $574,003
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $413,327