Finding 524106 (2024-004)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-02-20

AI Summary

  • Core Issue: CAP lacks a reliable internal control system for tracking costs charged to federal grants, leading to discrepancies between accounting records and reimbursement requests.
  • Impacted Requirements: Compliance with Uniform Guidance 2 CFR part 200.400, which mandates adequate documentation and consistent accounting practices for federal awards.
  • Recommended Follow-Up: CAP should enhance its policies and procedures for internal controls over grant expenditures to ensure accurate alignment with reimbursement submissions.

Finding Text

Material Weakness in Internal Control over Compliance 2024-004 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program: Community Services Block Grant (CSBG) & Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)(HCH). Federal Assistance Listing No: 93.569 and 93.224 County Recipient: Community Action Partnership of Natrona County Federal Agency: Department of Health and Human Services Grant year: 2023 and 2024 Federal Award Identification: Unknown Applicable Pass-through Entity: Wyoming Department of Health (CSBG), Direct (HCH) Criteria Accounting practices of the non-Federal entity must provide for adequate documentation to support costs charged to the Federal award. Standards for accounting practices in Uniform Guidance 2 CFR part 200.400 state that the accounting practices of the recipient and subrecipient must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the Federal award. Condition CAP was missing a consistent system of internal control for accumulation of costs charged to the federal program. The detail of costs maintained in the accounting system charged to the grants differed from the amounts included in the reimbursement requests. Cause Due to an accounting system conversion, adjustments were made in the general ledger to the beginning account balances. This resulted in unreconcilable differences from the detail in the accounting system after adjustment to what was originally submitted for reimbursement. Additionally, CAP began utilizing a separate payroll provider that required an integration of the payroll register monthly to the general ledger. Mapping and coding errors existed during the initial integrations of the payroll register to the general ledger resulting in additional differences from the general ledger to the amounts submitted for reimbursement for wage and benefit expense allocated to the grants. Effect or Potential Effect CAP was unable to provide an accurate accumulation of costs for amounts charged to the grant. Questioned Cost 93.224 - $9,274 93.569 - $28,355 Context The comparison of the general ledger for grant costs to the total of the amounts submitted for reimbursement resulted in differences of $9,274 for the Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) grant, and $28,355 Community Services Block Grant. Identification as a repeat finding This is not a repeat finding Recommendation We recommend CAP review its policies and procedures related to the internal controls over accumulation of expenditures related to grants to ensure the detail agrees to amounts submitted for reimbursement. Views of Responsible Officials Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. See Corrective Action Plan

Corrective Action Plan

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Categories

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties Cash Management HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 524107 2024-004
    Material Weakness
  • 524108 2024-005
    Significant Deficiency Repeat
  • 524109 2024-004
    Material Weakness
  • 524110 2024-004
    Material Weakness
  • 1100548 2024-004
    Material Weakness
  • 1100549 2024-004
    Material Weakness
  • 1100550 2024-005
    Significant Deficiency Repeat
  • 1100551 2024-004
    Material Weakness
  • 1100552 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.08M
93.569 Community Services Block Grant $704,243
21.032 Local Assistance and Tribal Consistency Fund $419,295
93.224 Covid-19 - Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $318,421
93.069 Public Health Emergency Preparedness $238,000
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $116,066
93.145 Hiv-Related Training and Technical Assistance $99,753
97.067 Homeland Security Grant Program $99,115
93.569 Covid-19 - Community Service Block Grant $91,580
93.268 Covid-19 - Immunization Cooperative Agreements $84,398
93.558 Temporary Assistance for Needy Families $69,966
93.959 Block Grants for Prevention and Treatment of Substance Abuse $69,943
14.267 Continuum of Care Program $60,290
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $53,586
95.001 High Intensity Drug Trafficking Areas Program $44,368
14.231 Covid-19 - Emergency Solutions Grant Program $41,471
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $41,356
93.387 National and State Tobacco Control Program $23,883
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $17,562
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $11,520
97.012 Boating Safety Financial Assistance $7,835
16.607 Bulletproof Vest Partnership Program $6,653
20.600 State and Community Highway Safety $5,884
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $3,391
20.616 National Priority Safety Programs $1,037