Finding 503562 (2022-005)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
$1
Year
2022
Accepted
2024-10-23

AI Summary

  • Core Issue: KCHC incurred $98,002 in costs after the allowed period of performance, violating federal regulations.
  • Impacted Requirements: Expenditures must be incurred within the specified period, and proper documentation is required to substantiate costs.
  • Recommended Follow-up: Implement a robust recordkeeping system to ensure timely documentation and compliance with performance period requirements.

Finding Text

Finding No. 2022-005 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Period of Performance Questioned Costs: $98,002 Criteria: In accordance with 45 CFR section 75.309, a non-federal entity may charge only allowable costs incurred during the period of performance and any costs incurred before the Health and Human Services (HHS) awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: For forty subsequent expenditures tested, aggregating $98,002 of a total population of $348,465, the following were noted: 1. For twenty-three (or 58%), expenditures were incurred and/or obligated after the obligation period of 04/30/2022. Finding No. 2022-005, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Period of Performance Questioned Costs: $98,002 Condition, continued: 2. For one (or 3%), cancelled check or other form of evidence (document no. 73206, dated 06/06/2022 amounting to $190) was not provided; accordingly, KCHC was not able to substantiate that the payment was liquidated within the grant award’s 120 days liquidation period, for which the amount is questioned. 3. For sixteen (or 40%), no supporting documents were provided to substantiate that the expenditures were incurred within the period of performance. Cause: KCHC did not enforce recordkeeping and monitoring controls over compliance with applicable period of performance requirements. Finding No. 2022-005, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Period of Performance Questioned Costs: $98,002 Effect: KCHC is in noncompliance with applicable period of performance requirements and questioned costs of $98,002 result. Recommendation: Responsible personnel should establish a recordkeeping system whereby underlying support for each transaction is timely provided and is filed to facilitate easy retrieval substantiating compliance. Identification as a Repeat Finding: Finding No. 2021-005 Views of Responsible Officials: KCHC’s Corrective Action Plan provides a rationale for disagreement with the finding. Auditor response: The supporting evidence provided indicates that the expenditures were incurred after the period of performance. Further, KCHC failed to provide evidence of certain expenditures being incurred within the corresponding period of performance. The finding remains.

Corrective Action Plan

Finding No. 2022-005 KCHC disagrees with the finding that it is in noncompliance with the applicable period of performance requirements. The sample request was received after the August 19 meeting with the CEO and board representative, during which it was noted that no further samples would be accepted as the audit had extended beyond one year. The delays were due to staffing challenges both on the part of the auditor and within KCHC. In FY 2025, KCHC has started the following corrective actions ensuring that all records are systematically filed and digitized for easy retrieval, regardless of changes in staff. This new system allows for seamless access to documents and a clear audit trail: 1. DocuSign for Document Management: In FY2025, KCHC adopted DocuSign to facilitate the management of financial documents. While DocuSign does not automatically upload supporting documents to the accounting software, it provides an efficient way to manage approvals and ensure an audit trail. After approval, the assigned accountant is responsible for manually uploading the supporting documents into the accounting software to ensure they are properly recorded and retrievable for audit purposes. 2. Timely Upload and Filing of Documentation: To address the delays, KCHC has updated its procedures requiring that all financial staff upload supporting documents at the time of expenditure approval or payment. This process will ensure that no documentation is missing or delayed, and all records are maintained in compliance with federal guidelines. 3. Ongoing Monitoring and Reporting: The CFO will oversee quarterly internal audits to ensure that the enhanced recordkeeping system is functioning effectively and that all expenditures continue to comply with the period of performance requirements. Progress will be reported to the Board of Directors to ensure transparency and ongoing compliance. By taking these corrective actions, KCHC will ensure that all expenditures are supported by proper documentation, uploaded timely, and readily available for audit review, preventing any future delays or compliance issues. Implementation Timeline: Completed as of August 31, 2024 with continued updates and monitoring. Responsible person: Arlene Deleon Guerrero, CFO

Categories

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles HUD Housing Programs Period of Performance

Other Findings in this Audit

  • 503560 2022-003
    Significant Deficiency Repeat
  • 503561 2022-004
    Significant Deficiency
  • 503563 2022-006
    Material Weakness Repeat
  • 503564 2022-007
    Material Weakness Repeat
  • 503565 2022-003
    Significant Deficiency Repeat
  • 503566 2022-004
    Significant Deficiency
  • 503567 2022-005
    Material Weakness Repeat
  • 503568 2022-006
    Material Weakness Repeat
  • 503569 2022-007
    Material Weakness Repeat
  • 503570 2022-003
    Significant Deficiency Repeat
  • 503571 2022-004
    Significant Deficiency
  • 503572 2022-005
    Material Weakness Repeat
  • 503573 2022-006
    Material Weakness Repeat
  • 503574 2022-007
    Material Weakness Repeat
  • 1080002 2022-003
    Significant Deficiency Repeat
  • 1080003 2022-004
    Significant Deficiency
  • 1080004 2022-005
    Material Weakness Repeat
  • 1080005 2022-006
    Material Weakness Repeat
  • 1080006 2022-007
    Material Weakness Repeat
  • 1080007 2022-003
    Significant Deficiency Repeat
  • 1080008 2022-004
    Significant Deficiency
  • 1080009 2022-005
    Material Weakness Repeat
  • 1080010 2022-006
    Material Weakness Repeat
  • 1080011 2022-007
    Material Weakness Repeat
  • 1080012 2022-003
    Significant Deficiency Repeat
  • 1080013 2022-004
    Significant Deficiency
  • 1080014 2022-005
    Material Weakness Repeat
  • 1080015 2022-006
    Material Weakness Repeat
  • 1080016 2022-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $100,511
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $85,996