Finding 508007 (2019-013)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2019
Accepted
2024-11-14

AI Summary

  • Core Issue: CHCC failed to maintain proper documentation for 82% of nonpayroll expenditures and several payroll transactions, leading to questioned costs of $22,500.
  • Impacted Requirements: Noncompliance with 2 CFR Part 200 regarding necessary and reasonable costs, as well as inadequate recordkeeping controls.
  • Recommended Follow-up: Implement a robust recordkeeping system to ensure all transactions have proper documentation before approval, and provide timely access to supporting records.

Finding Text

Finding No.: 2019-013 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Criteria: In accordance with 2 CFR Part 200, Subpart E, cost must be necessary and reasonable for the performance of the federal award and be allocable thereto. Further costs must conform to any limitations or exclusions and be adequately documented. Condition: Of thirty-three nonpayroll expenditures tested, aggregating $23,528 of a total population of $243,080, the following deficiencies were noted: 1. For twenty-seven (or 82%), check payments were not provided. In addition, for Document Numbers 1436562 and 1436565, funds availability certifications were not evident and payment request memorandums did not agree to the invoice amounts. Finding No.: 2019-013, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Condition, continued: 2. For three (or 9%), payment vouchers were not signed to evidence approval. 3. For one (or 3%), the P&S Director’s approval of the purchase order was not evident. No questioned costs is presented as the amount is questioned at Condition 1. Finding No.: 2019-013, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Condition, continued: Of thirty-two payroll expenditures tested, aggregating $26,611 of a total population of $535,817, the following deficiencies were noted: 4. For one (or 3%), approval of the Request for Personnel Action form by the Director of Public Health Services, Chief Financial Officer, Director of Human Resources and Chief Executive Officer were not evident. In addition, the payroll register was not provided to substantiate the employee’s payroll cost. 5. For one (or 3%), transaction pertains to personnel insurance costs, for which the corresponding supporting documents were not provided. 6. For five (or 15%), transactions pertain to payroll costs journal entries, for which the corresponding checks/ACH payments were not provided. Finding No.: 2019-013, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Cause: CHCC did not enforce recordkeeping controls in accordance with applicable allowable costs/cost principles requirements. Effect: CHCC is in noncompliance with allowable costs/cost principles requirements and questioned costs of $22,500 result as the projected questioned costs exceed the $25,000 threshold. Identification as a Repeat Finding: Finding No. 2018-020. Recommendation: The responsible personnel should establish a recordkeeping system whereby underlying support for each transaction is processed timely and filed accordingly for easy retrieval to substantiate costs. The responsible personnel should not approve program expenditures unless underlying support is provided for review. Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 1 and 2, and states agreement with Conditions 3 to 6; however, disagrees with the questioned costs. Finding No.: 2019-013, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Auditor Response: Condition 1 - Cancelled checks provided comprised of numerous invoice payments for which corresponding check vouchers were not provided; thus, CHCC was not able to substantiate whether cancelled checks provided pertain to transactions being tested. Condition 2 - Batch headers evidencing approvals were not provided. Conditions 3 through 6 - Questioned costs are warranted given transactions tested were not supported by adequate documentations. 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.: 2019-013 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreements Award Numbers: 6 NH23IP000736-05-01 and 5NH231P000736-05-00 Area: Allowable Costs/Cost Principles Questioned Costs: $22,500 Contact Persons: Perlie Santos, Chief Financial Officer; Emman Parian, Immunization Manager; Vincent Camacho, Grants Administrator; Chellah Sablan, Comptroller; Clarinda Ngirausui, Human Resources Manager; April Camacho, Payroll Supervisor. Corrective Action: Condition 1 CHCC does not concur with the findings and the $13,352 questioned costs. All the copies of the cleared checks were provided to the Auditors (Request# 53 and 54). Condition 2 CHCC does not concur with the findings and the questioned costs. The selected samples were part of a batch of invoices. The documentation of the approval was on the batch headers. The Auditors were only auditing for the manual approval stamp and signatures, when CHCC’s Financial Information system has embedded internal controls wherein the accounts payable accountants do not have access to post their own transactions. Transactions can only be posted after it is physically marked approved by the Accounting Managers in the JDE System and check payments cannot be printed when transactions are not posted for payment. Condition 3 We concur with the findings but not the questioned costs. Although not timely scanned and sent electronically to the Auditors, the Procurement Documents are available for testing. In fiscal year 2020, CHCC implemented the document routing repository for the procurement process using Laserfiche Forms. This will enable CHCC to warehouse all supporting documentation related to procurement activities and document the approval process. With the implementation of the Munis Financial Information System in January 2023, CHCC is now able to electronically attach scanned supporting documents to the vouchers through the Tyler Content Manager (TCM). This will allow for audit testing to be done by providing auditors view only access to CHCC Financial Information System. Finding No.: 2019-013, Continued Condition 4 to 6 We concur with the finding but not the questioned cost. The Human Resources Department was not able to timely locate the personnel action file and although payroll was able to provide the payroll registers, we were not able to provide them in excel format to facilitate the audit. CHCC will roll out on December 2024, the Tyler Munis Human Capital Management Module, wherein all personnel action will be processed through electronic workflow and will be saves in the Tyler Content Manager in electronic format. This will also streamline documentation for payroll processing. This will resolve the issue of unlocated files. Proposed Completion Date: On-Going

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 507998 2019-004
    Material Weakness Repeat
  • 507999 2019-005
    Material Weakness Repeat
  • 508000 2019-006
    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
  • 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