Finding Text
Assistance Listing, Federal Agency, and Program Name 93.224, 93.527; COVID 19: Health Center Program Cluster
Federal Award Identification Number and Year H80CS24134, H8ECS37956, H8FCS40356, and H8GCS48255 2022
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria In accordance with the Declaration and Certification made to the U.S. Department of Health and Human Services at the time of drawdown and the Organization's internal policy, the Organization must disburse funds for costs that are reasonable, allowable, and allocable to the award within three business days or immediately return the funds.
Condition The Organization maintains and tracks federal expenditures incurred for the year in totality, however, does not maintain adequate records to track the costs applied to each individual draw down made throughout the year. Without this linkage, the timeliness between draw down and disbursement to ensure the disbursement occurred prior to or within three business days of draw down is unable to be validated.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context During cash management testing, supporting documentation to identify the costs applied to each drawndown was not maintained for all 8 samples tested. During allowability testing, none of the 30 samples tested were able to be traced to a specific draw down to validate the cost was paid within three business days. However, in total for the year the Organization was able to support the draws received with a detailed listing of federal expenditures as reported on the SEFA.
Cause and Effect Insufficient controls are in place over cash management. As a result, cash drawdowns were made throughout the year with no linkage to specfic federal expenditures and thus the Organization did not comply with the related compliance requirement.
Recommendation We recommend the Organization implement controls over cash management, including layers of review, to ensure supporting documentation to link federal expenditures to each drawdown is maintained and the timely disbursement of funds received.
Views of Responsible Officials and Planned Corrective Actions The Organization will implement controls, including layers of review, to ensure supporting documentation to link federal expenditures to each drawdown is maintained and the timely disbursement of funds received.