Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024
Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024
Community Health Center Program – State Identifying No. 435.151301
Wisconsin Department of Health
Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024
Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023
Criteria or Specific Requirement – Allowable Costs/Cost Principles – Federal: 45 CFR 75.403. State: Wisconsin Department of Health Services Allowable Cost Policy Manual (ACPM) and 2 CFR 200.403.
Condition – Costs were included as a cost on more than one federal and/or state award program in the current period.
Questioned Costs – Federal: $88,199. State: $4,792. Questioned costs were determined by identifying all employees who appeared on more than one grant expenditure listing and reviewing the specific payroll periods charged to each award for duplicates. Questioned costs by federal award identification number are:
• Assistance Listing No. 93.224 Award No. 6 H8FCS41089 and Agreement No. 435100-G24-3919588107-390 - $2,056
• Assistance Listing No. 93.527 Award No. 6 H80CS00751 and Agreement No. 435100-G24-3919588107-90 – $2,736
• Assistance Listing No. 93.527 Award No. 6H80CS00751 and Assistance Listing No. 93.224 Award No. 6 H8FCS41089 – $83,407
Context – Salaries and wages for two employees of the Organization were identified as being charged to both Award No. 6 H80CS00751 and 6 H8FCS41089 within the Health Center Program Cluster (HCP) for five to seven months during the fiscal year. For two other employees, salaries and wages were identified as being charged to both the Wisconsin Department of Health Community Health Center Program (CHCG) and one of the awards in the HCP, but instances were limited to only certain payroll periods.
Effect – The Organization charged payroll expenditures to more than one funding stream within the HCP and CHCG grant awards.
Cause – Salaries and wages are charged to federal and state awards through separate manual tracking spreadsheets, which link back to payroll supporting documentation summarized monthly based on pay date. The Organization’s internal controls intended to prevent charging amounts to more than one award includes a separate spreadsheet listing all employees and identifying the budgeted percentage of salaries and wages associated with each federal and state awards. The system was not accurately updated to reflect changes throughout the year or monitored when the Organization prepared “catch-up” drawdowns after-the-fact to justify use of remaining available grant funds.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – The Organization should consolidate tracking of salaries and wages charged to federal and state awards into a single listing for each payroll period rather than separate spreadsheets based on summarized monthly payroll data. The Organization should support the distribution of employees’ salaries and wages amongst federal and state awards to accurately reflect the work performed through the timekeeping system and payroll records.
Views of responsible officials and planned corrective actions – Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period.
The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.