Finding Text
Criteria: 2 CFR 200.303 states a non-Federal entity must establish and maintain effective internal controls 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.
Condition: During our audit, auditors tested 25 employees for completion certificate of required training as a condition of the grants. Three of the required annual training were significantly non-compliant.
• The Annual HIPPA Training 23 of the 25 (92%) of employees did not properly complete the training.
• The Annual Security Awareness Training 4 of the 25 (16%) of employees did not properly complete the training.
• The Annual Service Delivery for Deaf and Hard of Hearing Training 15 of the 25 (60%) of employees did not properly complete the training.
Questioned Costs: No questioned costs were noted.
Cause: The cause of this condition appears to be a lack of oversight in monitoring training completion records and insufficient internal controls over training compliance.
Effect: Failure to properly complete required training increases the risk of noncompliance with federal program requirements, potentially leading to disallowed costs, penalties, or other adverse consequences.Recommendation: We recommend that management, enhance internal controls over training compliance by implementing more effective tracking and monitoring system and assign responsibility for ensuring timely completion of required training to a specific individual or department.
Additionally, we recommend Hibiscus consider implementing a rolling-year training schedule rather than an annual hire-date renewal process. This approach can streamline tracking, reduce administrative burdens, and ensure consistent compliance by aligning training requirements with a standard cycle applicable to all employees.