Finding Text
Finding Number: 2023-002
Finding Type: Federal award finding
Federal Assistance Listing No.: 93.421
Program Name: Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Entity: n/a
Grant Number: 6 NU38OT000281-05-02
Federal Award Year: 2023
Control Deficiency Type: Significant deficiency over compliance
Instance of Noncompliance: No
Compliance Requirement: Cash Management, Allowable Costs, Procurement
Questioned Costs: None
Repeat Finding: No
Criteria: The OMB’s Uniform Guidance requires nonfederal entities to have certain written policies and procedures surrounding the management of their award funds. More formally known as the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Among other requirements, the Uniform Guidance specifically requires written policies in these areas: advance payments and reimbursements (“cash management”), allowable costs, and procurement.
Condition: The organization did not have the written policies and procedures required by the OMB’s Uniform Guidance.
Cause: The organization was unaware of the Uniform Guidance’s written policies requirement.
Effect: Sound internal control can only be effected when the organization’s management monitors compliance with established policies and procedures throughout all levels of the organization and on a continuous basis. Failure to maintain written policies and procedures and monitor the adherence to those policies and procedures may result in noncompliance with regard Uniform Guidance as well as the organization’s internal policies.
Audit Recommendation: We recommend that management prepare a manual of financial and federal compliance policies and procedures and ascertain that the manual is complete, accurate and includes all written policies required by the Uniform Guidance. Once completed, the manual should be distributed to all appropriate employees, and training as well as monitoring procedures should be instituted to ensure that all employees comply with the organization’s policies to ensure the management and expenditure of federal awards are in compliance with Uniform Guidance.
Management’s Response: We will prepare the manual of financial and federal compliance policies and procedures (including cash management, allowable costs, and procurement) as required by the Uniform Guidance. Pertinent employees will be trained to use this manual to ensure compliance.