Finding Text
Finding 2023-004 – Internal Control Deficiency Reporting
Identification of the federal program:
Federal grantor: United States Department of Health and Human Services
Assistance listing no.: 93.048
Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The individual who prepares the SF-425 report was the same individual who reviewed and submitted the reports.
Cause:
Controls were not designed effectively throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission.
Effect or potential effect:
Reports could reflect inaccurate information.
Questioned costs:
None.
Context:
Because there was not appropriate segregation of duties throughout the audit period, we did not test internal controls over reporting.
Identification as a repeat finding, if applicable:
This is a repeat finding – Finding 2022-003.
Recommendation:
AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission to ensure reports are complete and accurate.
View of responsible officials:
Management agrees with the finding. Controls were enhanced in October 2023 whereby the person preparing the reports is independent of the person reviewing the reports.