Finding Text
2023-004 Substance Abuse Prevention and Treatment Block Grant - Assistance Listing No. 93.959;
Oregon Health Authority Subgrant No. 167552; Grant period - Year ended June 30, 2023.
Compliance Requirements: Allowable Activities and Allowable Costs
Criteria and Condition: Title 2 U.S. Code of Federal Regulations 200.303 Internal Controls requires
grantees to establish and maintain internal controls sufficient to provide reasonable assurance of
compliance with applicable statutes, regulations, and terms and conditions of Federal awards. Internal
controls related to the review and approval of non-payroll costs were not operating effectively throughout
the grant period.
Context: Twenty-five non-payroll expenses were selected for testing. The invoice for one of the selected
items could not be located; as such, no evidence was available to demonstrate the operation of review
and approval controls. The provided invoice and support for two additional items selected for testing did
not show evidence of being reviewed. The three items were not determined to be instances of
noncompliance as the information avaliabe was sufficient to demonstrate compliance with allowable
activity and allowable cost requirements.
Cause: Processes and procedures were not sufficient to ensure that evidence of the performance of
internal controls was readily available for all grant expenditures.
Effect: If not reviewed and approved according to HIV Alliance's policies, unallowable activities and costs
could be funded with federal awards and result in instances of noncompliance.
Recommendation: Processes and procedures should be reviewed and strengthened to ensure all
controls are appropriately documented and available for review by internal and external parties at a later
date.
Management's Response: Processes will be implemented and monitored to ensure all expenses include
evidence of the review and approval procedures performed.