Finding Text
Assistance Listing Number 93.917 – HIV Care Formula Grants, award numbers: FAIN#X070028
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: At times in 2023, approval of expenditures did not follow stated polices, or documentation of approval was not retained.
Cause: The Executive Director approves expenditures; however, a process was not consistently in place to show documentation of the approval. At times, approval was done verbally and documentation of the approval was not retained.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: As of the date of testing, documented approval was not available for twenty-eight of forty items selected for assistance listing 93.917.
Recommendation: We recommend the Organization obtain approval of all expenses by a member of management that did not initiate the expense, prior to the expenses being charged to a federal grant.
Planned Corrective Action: We agree in part to this finding. The deficiency exists with approval of transactional funds that are utilized for the transportation and food voucher programs. Historically, authorization to purchase has been deemed as approval and this year some of those documentation processes were not consistently followed, as mentioned being done verbally or during other discussions that were not documented. We did not make any food voucher purchases without discussion prior to purchasing. That being said, we can formalize an approval process that is documented.
Additionally, we will review our transportation program policies to ensure that a proper approval process is in place and continues to be supported by the processes we have in place.
Name of Contact Person: Drayke Standing Bear, Support Services Coordinator (drayke@raan.org or 320-257-3036) and Courtney Eckstein, Medical Case Management Coordinator (courtney@raan.org or 507-720-2224).
Anticipated completion date: December 1, 2024