Finding Text
Activities Allowed or Unallowed
Allowable Costs and Cost Principles
U.S. Department of Public Health
ALN: 93.829, Central Montana Certified Community Behavioral Health Clinic Expansion Project
Criteria: The funds are to be used primarily to support direct treatment services for individuals impacted by the COVID-19 pandemic. No more than 15 percent of the total grant award for each budget period may be used for data collection, performance measurement, and performance assessment, including incentives for participating in the required data collection follow-up. Up to $25,000 of the annual grant award for each budget period may be used to purchase technical assistance. If technical assistance is not needed, the recipient may use those funds for allowable or required activities.
Condition: The Center was unable to provide support demonstrating the tracking and internal controls used to monitor the 15 percent requirement and the $25,000 technical assistance limit requirement. The Center supplied prepared financial statements for each quarter, which supported the amounts claimed as used with these funds. However, transaction detail of what made up these totals could not be provided.
Context: There are two 12-month incremental periods in this award; the first restricts the recipient from spending more than $2,000,000 from 2/15/2021 to 2/14/2022, and the second period is also limited to $2,000,000 for the period covering 2/15/2022 to 2/14/2023. Staff prepared financial statements for each quarter that showed total income received and expenses incurred for the program.
Effect: We were unable to determine if the Center complied with the 15 percent requirement or the $25,000 technical assistance limit. We were also unable to test a sample of direct costs charged to the program since transaction details supporting the prepared financial statements were not provided.
Questioned Costs: We were unable to determine if there were any questioned costs.
Cause: The Center has financial statements and spreadsheets showing what costs were attributable to this program, but we were not provided with information showing the tracking of these requirements or details of these costs. Staff responsible for tracking this information are no longer employed with the Center.
Auditor Recommendation: We recommend that the Center implement procedures to adequately retain supporting documents for federal programs.
Organization Response: The Staff Accountant will retain in hard copy and/or electronic form all supporting documentation of costs attributable to the CCBHC grant. Electronic records of grant transactions will be kept on CFMH one drive cloud, and printed copies will be kept in a grant folder. This includes but is not limited to all requests and approvals of expenditures, drawdowns, and any funding revisions and approvals. The supporting documents substantiating specific revenue and expense detail for the transactions will be uploaded and attached to the specific journal entry in Intacct. It will be the responsibility of the Accounting Manager (or Controller in the absence of the Accounting Manager) to monitor compliance with the retention of all supporting documentation by the Staff Accountant. The Accounting Manager (or Controller in the absence of the Accounting Manager) will be responsible for tracking and monitoring that no more than 15% of the total grant award for each budget period will be used for costs related to data collection, performance measurement, and performance assessment. The Accounting Manager (or Controller in the absence of the Accounting Manager) will also be responsible for tracking and monitoring that no more than $25,000 of the annual grant award for each budget period may be used for costs related to the purchase of technical assistance. The Center for Mental Health policies and procedures have been updated to include this additional level of accountability and internal control.