FAC Explorer

Finding 49953 (2022-006)

Significant Deficiency Repeat Finding
Requirement
H
Questioned Costs
$1
Year
2022
Accepted
2023-06-28
Audit: 46560
Organization: Population Services International (DC)
Auditor: Bdo

AI Summary

  • Core Issue: Expenses totaling $1,725 were incurred after the award's period of performance, leading to noncompliance with federal regulations.
  • Impacted Requirements: Non-Federal entities must only charge allowable costs incurred during the specified period and liquidate obligations within 120 days post-award.
  • Recommended Follow-Up: Revise internal procedures to better detect out-of-period expenses and consider closing projects in the accounting system to prevent future issues.

Finding Text

2022-006 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement See Schedule of Findings and Questioned Costs for chart/table Criteria or Specific Requirement: In accordance with ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: We identified 12 instances out of 162 sample items selected, whereby expenses were incurred after the end of the award period of performance. These expenses totaled $1,725 for Award NU2GGH002005. Questioned Costs: For Award NU2GGH002005, we identified $1,557 in known questioned costs as a result of our sampling and testing procedures related to the close-out period of the award. Further analysis of the population of expenses incurred during the close-out period resulted in the identification of an additional $16,690 in known questioned costs that were outside of the period of performance and not permitted to be charged to the award based on the terms of the close-out budget. In addition, we identified $168 in known questioned costs as a result of our testing procedures for the period of performance of the original term of Award NU2GGH002005. Likely questioned costs associated with expenses incurred outside the period of performance of the original award totaled $83,585. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected as part of our testing of allowable costs and allowable activities were incurred within the proper period of performance of the award. Testing of those 120 expenses for AL# 93.067 resulted in one exception totaling $33 related to Award NU2GGH002005 (included in the questioned costs of $168 above), and testing of 120 expenses for AL# 98.NoAL resulted in no exceptions to the period of performance requirements. BDO also performed specific period of performance procedures on those awards that began or ended during 2022. A total of 42 expenses for AL# 93.067 were selected across the awards that began or ended during 2022, and the compliance matters identified above resulted from those specific 42 items tested for AL# 93.067. No specific period of performance procedures were required for AL# 98.NoAL based on the individual grant period(s) of the awards. Cause: PSI management has procedures in place to review expenditures to determine the appropriate period of performance; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. Effect: The lack of adherence to the established internal control procedures around the period of performance of the award resulted in noncompliance and questioned costs that need to be returned to the U.S. Department of Health and Human Services. Continued noncompliance with federal statutes, regulations, and the provisions of the grant agreements could ultimately result in additional disallowed costs for the major programs. Repeat Finding: This finding is a repeat finding from 2021 and was reported as finding 2021-006 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance in order to prevent the charging of costs outside of the period of performance of the award. Furthermore, we believe an option would be to close the project within the accounting system, and create a separate project to accumulate any costs incurred after the end of the period of performance. The costs incurred subsequent to the end of the period of performance should go through the review and approval of individuals at PSI Headquarters. Views of Responsible Officials: PSI management agrees with the finding and recommendations set forth within and will provide training to appropriate staff responsible for monitoring expenses on the program. Refer to management?s corrective action plan for additional information.

Corrective Action Plan

2022-006 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Contact: Chris Holmes Title: Controller Phone Number: 202-235-1938 Estimated Completion Date ? done Corrective Action The results of the 2022 audit will be shared with appropriate staff and reiterated in training to ensure that adequate attention and guidance is provided on the allowability of trailing costs and the unallowability of newly incurred costs. From 2023, PSI will resume delivering in person training to its global finance and program staff.

Categories

Questioned Costs Subrecipient Monitoring Period of Performance

Other Findings in this Audit

  • 39494 2022-005
    Significant Deficiency Repeat
  • 39495 2022-005
    Significant Deficiency Repeat
  • 39496 2022-005
    Significant Deficiency Repeat
  • 39497 2022-001
    Significant Deficiency Repeat
  • 39498 2022-005
    Significant Deficiency Repeat
  • 49946 2022-002
    Significant Deficiency Repeat
  • 49947 2022-005
    Significant Deficiency Repeat
  • 49948 2022-002
    Significant Deficiency Repeat
  • 49949 2022-005
    Significant Deficiency Repeat
  • 49950 2022-002
    Significant Deficiency Repeat
  • 49951 2022-004
    Significant Deficiency
  • 49952 2022-005
    Significant Deficiency Repeat
  • 49954 2022-002
    Significant Deficiency Repeat
  • 49955 2022-001
    Significant Deficiency Repeat
  • 49956 2022-003
    Significant Deficiency
  • 49957 2022-001
    Significant Deficiency Repeat
  • 49958 2022-004
    Significant Deficiency
  • 615936 2022-005
    Significant Deficiency Repeat
  • 615937 2022-005
    Significant Deficiency Repeat
  • 615938 2022-005
    Significant Deficiency Repeat
  • 615939 2022-001
    Significant Deficiency Repeat
  • 615940 2022-005
    Significant Deficiency Repeat
  • 626388 2022-002
    Significant Deficiency Repeat
  • 626389 2022-005
    Significant Deficiency Repeat
  • 626390 2022-002
    Significant Deficiency Repeat
  • 626391 2022-005
    Significant Deficiency Repeat
  • 626392 2022-002
    Significant Deficiency Repeat
  • 626393 2022-004
    Significant Deficiency
  • 626394 2022-005
    Significant Deficiency Repeat
  • 626395 2022-006
    Significant Deficiency Repeat
  • 626396 2022-002
    Significant Deficiency Repeat
  • 626397 2022-001
    Significant Deficiency Repeat
  • 626398 2022-003
    Significant Deficiency
  • 626399 2022-001
    Significant Deficiency Repeat
  • 626400 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
98.U00 Advancing Progress in Malaria Service Delivery $41.67M
98.001 Going the Last Mile for Hiv Control $20.40M
98.001 Momentum Targeted Mnch/fp/rh Technical Assistance to Private Providers $19.95M
98.001 Angola Health for All $11.66M
98.001 Improving Market Partnerships and Access to Commodities Together (impact) $10.87M
98.001 Donated Commodities $8.26M
98.U00 Donated Commodities $6.73M
93.067 Provision of Voluntary Medical Male Circumcision (vmmc) for Hiv Prevention in the Republic of South Africa Under the President's Emergency Plan for Aids Relief (pepfar) $6.70M
98.U00 Global Health Supply Chain (gshc) - Procurement and Supply Management (psm) $6.09M
98.001 Ethiopia Transform: Water, Sanitation and Hygiene $5.73M
98.001 Stop Djekoidjo $4.34M
98.001 Hiv Services for Key and Priority Populations $4.33M
98.001 Covid-19 - Angola Health for All $3.94M
98.001 Expanding Malawi Hiv-Aids Prevention with Local Organizations Working for An Effective Epidemic Response (empower) $3.82M
98.U00 Vector Control Indefinite Delivery Indefinite Quantity Contract (vc Idiq", Project") $3.53M
98.001 Cambodia Promoting Healthy Behaviors Activity $3.50M
98.001 Samagra: A Total Market for Comprehensive Consumer-Empowered Primary Health $3.16M
93.067 Scaling Up Targeted Hiv Testing Services and Linkage to Treatment $2.94M
98.001 Covid -19 - Going the Last Mile for Hiv Control $2.83M
12.350 Cdi Dhapp Faci Partnership for Sustainable Hiv Epidemic Control $2.66M
93.067 Improving Hiv/sti/tb Prevention, Treatment and Care Services for Mobile Populations $2.36M
93.067 Strategic Scale Up of Community Based Hiv Testing and Counseling $2.33M
12.350 Burundi National Defense Force (bndf) Partnership for Sustainable Hiv Epidemic Control $2.13M
98.001 Tubiteho $1.93M
98.001 Tb/hiv Agency, Information and Services $1.65M
98.001 Covid -19 - Meeting Targets and Maintaining Epidemic Control (epic) $1.56M
98.001 Enhancing Quality of Healthcare Activity $1.31M
98.001 Improved Family Planning Initiative $1.13M
98.001 Evaluation Innovative Technologies and Approaches to Addressing Cervical Cancer in the Republic of Mozambique $1.04M
98.001 Hiv Prevention for High Risk Individuals $1.04M
98.001 Madagascar's Accessible Continuum of Care and Essential Services Sustained (access) $902,728
98.001 Countywide Sanitation Activity (cwsa) $725,677
98.001 Myanmar Essential Health Services Program $706,979
98.001 Expanding Contraception $664,246
12.350 Lesotho-Military Specific Hiv/aids Prevention, Care, and Treatment Program for Pepfar Funded Countries $606,476
98.001 Tanzania Malaria Case Management Activity $578,095
98.001 Mozambique Small Town Sanitation Project $525,474
98.001 The Kampala Slum Maternal Newborn Project: Innovating for Better Systems Outcomes $441,658
12.350 Central America Regional Partnership for Sustainable Hiv Epidemic Control in the Guatemalan, Honduran and Salvadoran Militaries $423,396
98.U00 Usaid West Africa Municipal Wash (muniwash) $405,921
98.001 Research for Scalable Solutions (r4s) $381,148
93.067 Recent Infection Surveillance Consortium $341,069
98.001 Covid -19 - Path and the Digital Health Initiative - Accelerating the Cycle for Investment $332,189
98.U00 Usaid Western Kenya Sanitation Project (wksp) $310,541
98.001 Covid - 19 - Expanding Malawi Hiv-Aids Prevention with Local Organizations Working for An Effective Epidemic Response (empower) $290,891
98.001 Covid-19 - Samagra: A Total Market for Comprehensive Consumer-Empowered Primary Health $265,928
93.067 Donated Commodities $232,586
98.001 Covid - 19 - Hiv Services for Key and Priority Populations $228,607
98.U00 Covid -19 - Advancing Progress in Malaria Service Delivery $219,882
98.001 Unaids in Support of the Unified Budget and Workplace $198,671
98.001 Digital Health Initiative Accelerating the Cycle of Investment to Impact in Global Digital Health $197,669
98.001 Next Generation Products for Prevention of Hiv Infection in Women (nix Hiv) $148,796
98.001 Health and Hygiene Project $117,889
12.350 Advancing Multi-Country Hiv Support in Collaboration with Dhapp and Partner Militaries for Sustainable Hiv Epidemic Control (multi-Country) $114,693
98.001 Covid - 19 - American Rescue Plan Act (arpa) Covid-19 Support $71,062
93.318 Covid-19 Vaccination Program Support in Eswatini $70,386
98.001 Covid -19 - Ethiopia Transform: Water, Sanitation and Hygiene $52,331
98.001 Usaid Hiv Prevention, Testing and Treatment Services for Key Populations $48,592
98.001 Growth Through Nutrition $41,861
98.001 Bangladesh Marketing Innovations for Sustainable Health Development $41,091
93.067 Covid-19 - Improving Hiv/sti/tb Prevention, Treatment and Care Services for Mobile Populations $40,372
93.067 Covid - 19 - Strategic Scale Up of Community Based Hiv Testing and Counseling $32,282
98.001 Covid -19 - Research for Scalable Solutions (r4s) $7,738
98.001 High Impact Maternal, Newborn and Child Health (hi-Mnch) Activity $3,767
98.001 Family Planning Integrated Project $-5
12.350 Hiv/aids Prevention, Care and Treatment Support to the South African National Defense Force $-42
98.001 Meeting Targets and Maintaining Epidemic Control (epic) $-107
19.703 Costa Rica - Building Capacity to Prevent and Address Domestic Violence $-161
93.067 Covid -19 - Scaling Up Targeted Hiv Testing Services and Linkage to Treatment $-279
93.067 Programmatic Implementation and Technical Assistance (ta) for Hiv/aids $-702
98.001 Sustaining Health Outcomes Through the Private Sector Project Plus (shops Plus) $-874
93.067 Accelerating Epidemic Control in 7 Districts of Mubende Region in the Republic of Uganda Under the President's Emergency Plan for Aids Relief (pepfar) $-1,981
98.001 Zimbabwe Strengthening Private Sector Services Project $-962,286