FAC Explorer

Finding 508000 (2019-006)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2019
Accepted
2024-11-14
Audit: 328484
Organization: Commonwealth Healthcare Corporation (MP)
Auditor: Ernst & Young (cnmi) INC

AI Summary

  • Core Issue: CHCC failed to provide necessary documentation for non-federal matching funds, leading to noncompliance with federal requirements.
  • Impacted Requirements: This affects compliance with 2 CFR Subpart 200.306, specifically regarding verifiable contributions and internal controls.
  • Recommended Follow-Up: CHCC should implement a robust recordkeeping system to ensure all matching requirements are documented and maintained.

Finding Text

Finding No.: 2019-006 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Award Number: 6U79SM062447-04M001 and 6U79SM062447-04M004 Area: Matching, Level of Effort, Earmarking Questioned Costs: $-0- Criteria: In accordance with 2 CFR Subpart 200.306, for all Federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-Federal entity's cost sharing or matching when such contributions meet all of the following criteria: 1. Are verifiable from the non-Federal entity's records; 2. Are not included as contributions for any other Federal award; 3. Are necessary and reasonable for accomplishment of project or program objectives; 4. Are allowable under subpart E of this part; 5. Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; 6. Are provided for in the approved budget when required by the Federal awarding agency; and 7. Conform to other provisions of this part, as applicable. Condition: Support for the non-federal match for Business Units H71040 and H81040 were not provided. Cause: CHCC did not enforce internal controls over recordkeeping and monitoring controls to substantiate compliance with matching requirements. Effect: CHCC is in noncompliance with applicable matching requirements. No questioned costs are presented as we are unable to quantify the extent of noncompliance. Finding No.: 2019-006, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Award Number: 6U79SM062447-04M001 and 6U79SM062447-04M004 Area: Matching, Level of Effort, Earmarking Questioned Costs: $-0- Identification as a Repeat Finding: Finding No. 2018-012. Recommendation: Responsible CHCC personnel should establish recordkeeping system whereby underlying support for matching requirements is substantiated and filed. Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding. Auditor Response: Underlying accounting records supporting the non-federal match were not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.

Corrective Action Plan

Finding No.: 2019-006 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Award Number: 6U79SM062447-04M001 and 6U79SM062447-04M004 Area: Matching, Level of Effort, Earmarking Questioned Costs: $-0- Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator. Corrective Action: CHCC does not concur with these findings. CHCC affirms that the Match used to support activities of H71040 and H81040 were from verifiable records, and not from other federal funds. Costs were reasonable and necessary to accomplish the program’s objectives and were provided to and approved by the awarding agency. Finding No.: 2019-006 Continued Furthermore, CHCC sought clarification with SAMHSA and received notice that a match waiver for the Territories of up to $200,000 is applicable to all SAMHSA grants received based on the following federal statute: “Pub. L. 96-205, title VI, Sec. 601, Mar. 12, 1980, 94 Stat. 90, as amended Pub. L. 98-213, Sec. 6, Dec. 8, 1983, 97 Stat. 1460; Pub. L. 98-454, title VI, Sec. 601(b), Oct. 5, 1984, 98 Stat. 1736, subsection (d): ``Notwithstanding any other provision of law, in the case of American Samoa, Guam, the Virgin Islands, and the Northern Mariana Islands any department or agency shall waive any requirement for local matching funds under $200,000 (including in-kind contributions) required by law to be provided by American Samoa, Guam, the Virgin Islands, or the Northern Mariana Islands. Therefore, whatever match amount required per year should be reduced by $200,000 for the Northern Mariana Islands. Summarized below are the required and reported match amounts derived from the Final FFR for Grant SM062447, which included activities for H71040 and H81040 for fiscal year 2019. SOC_CHH61040_Matching_Revised013019.docx SOC_CHH71040 Matching.docx SOC_CHH81040_FY19 Matching.docx SOC_CHH81040_NCE Matching.docx Proposed Completion Date: Not applicable as CHCC does not concur with the findings.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 507998 2019-004
    Material Weakness Repeat
  • 507999 2019-005
    Material Weakness Repeat
  • 508001 2019-007
    Material Weakness Repeat
  • 508002 2019-008
    Material Weakness Repeat
  • 508003 2019-009
    Material Weakness
  • 508004 2019-010
    Material Weakness
  • 508005 2019-011
    Material Weakness Repeat
  • 508006 2019-012
    Material Weakness Repeat
  • 508007 2019-013
    Material Weakness Repeat
  • 508008 2019-014
    Material Weakness
  • 508009 2019-015
    Material Weakness
  • 508010 2019-016
    Material Weakness Repeat
  • 1084440 2019-004
    Material Weakness Repeat
  • 1084441 2019-005
    Material Weakness Repeat
  • 1084442 2019-006
    Material Weakness Repeat
  • 1084443 2019-007
    Material Weakness Repeat
  • 1084444 2019-008
    Material Weakness Repeat
  • 1084445 2019-009
    Material Weakness
  • 1084446 2019-010
    Material Weakness
  • 1084447 2019-011
    Material Weakness Repeat
  • 1084448 2019-012
    Material Weakness Repeat
  • 1084449 2019-013
    Material Weakness Repeat
  • 1084450 2019-014
    Material Weakness
  • 1084451 2019-015
    Material Weakness
  • 1084452 2019-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $3.68M
93.268 Immunization Cooperative Agreements $3.36M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $1.97M
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $865,589
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $763,992
93.982 Mental Health Disaster Assistance and Emergency Mental Health $613,302
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $589,264
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $544,042
15.875 Economic, Social, and Political Development of the Territories $533,528
97.032 Crisis Counseling $501,942
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $494,660
93.994 Maternal and Child Health Services Block Grant to the States $452,851
93.236 Grants to States to Support Oral Health Workforce Activities $331,358
93.217 Family Planning Services $272,252
93.251 Universal Newborn Hearing and Screening $269,168
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $258,698
93.959 Block Grants for Prevention and Treatment of Substance Abuse $233,626
93.165 Grants to States for Loan Repayment $125,000
93.945 Assistance Programs for Chronic Disease Prevention and Control $120,169
93.917 Hiv Care Formula Grants $115,562
93.958 Block Grants for Community Mental Health Services $110,106
93.110 Maternal and Child Health Federal Consolidated Programs $89,729
93.644 Adult Medicaid Quality: Improving Maternal and Infant Health Outcomes in Medicaid and Chip $86,496
93.069 Public Health Emergency Preparedness $69,626
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $66,588
93.377 Prevention and Control of Chronic Disease and Associated Risk Factors in the U.s. Affiliated Pacific Islands, U.s. Virgin Islands, and P. R. $65,865
93.314 Early Hearing Detection and Intervention Information System (ehdi-Is) Surveillance Program $64,766
93.504 Family-To-Family Health Information Centers $63,569
93.788 Opioid Str $57,326
93.150 Projects for Assistance in Transition From Homelessness (path) $53,208
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $46,310
93.991 Preventive Health and Health Services Block Grant $39,096
93.889 National Bioterrorism Hospital Preparedness Program $32,585
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $16,318
97.088 Disaster Assistance Projects $12,625
10.855 Distance Learning and Telemedicine Loans and Grants $6,162
93.817 Hospital Preparedness Program (hpp) Ebola Preparedness and Response Activities $4,921
93.103 Food and Drug Administration Research $4,911
10.578 Wic Grants to States (wgs) $3,323
16.575 Crime Victim Assistance $1,379