Finding 529530 (2022-007)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2025-03-24
Audit: 347522
Organization: National Indian Health Board (DC)
Auditor: Sikich CPA LLC

AI Summary

  • Core Issue: Lack of proper monitoring and documentation for subrecipients, including checks for suspension or debarment.
  • Impacted Requirements: Failure to meet annual monitoring criteria and follow-up on audit findings as mandated by 93.421.
  • Recommended Follow-Up: Implement annual checks for subrecipients, maintain documentation, and ensure timely follow-up on audit findings to comply with Uniform Guidance.

Finding Text

2022-007 Improper monitoring of subrecipients 93.421 Strengthening Public Health Systems and Services Audit Results: Criteria:Organizations should check the status of subrecipients at least annually and maintain documentation as evidence. In addition, if their are findings on the audited financial statements of a subrecipient, there should be follow-up to determine the status of those findings in subsequent years. Condition:Auditors noted there was no documentary evidence of a check for suspension or debarment for any of the subrecipients and in addition there was no follow up on the audit findings for subrecipient. Effect:As a result, the Organization was missing documentation relating to subrecipient monitoring requirements for the year ended December 31, 2022. Cause:This is due to ineffective controls over subrecipient monitoring resulting in a lack of documentation, miscommunications during employee transitions and the need to train new employees on policies and procedures. Recommendation: Auditors recommend that there are checks at least annually for suspension or debarment and that documentation be maintained for all checks completed. In addition the Organization should follow up and obtain audited financial statements each year from subrecipients or other documentation showing the status of audit findings. It is critical that subrecipients are properly monitored to ensure that they are complying with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

Summary of Finding Improper monitoring of subrecipients: Auditors noted there was no documentary evidence of a check for suspension or debarment for any of the subrecipients and in addition there was no follow up on the audit findings for subrecipient. As a result, the Organization was missing documentation relating to subrecipient monitoring requirements for the year ended December 31, 2022. Statement of Concurrence or Nonconcurrence This finding was concurred with due to staff turnover and the department being short-staffed. Corrective Action In response to the findings on subrecipient monitoring, the Organization has updated its Grant Cycle Standard Operating Procedures to align with OMG Uniform Guidance. These revised procedures now require documented checks for suspension or debarment for all subrecipients, along with mandated follow-up on any subrecipient audit findings. In addition, all staff have received enhanced training on these requirements, and the onboarding process has been updated to include a focused review of subrecipient monitoring. Finally, a new position has been established to manage vendor purchase orders and maintain comprehensive sourcing documentation, thereby strengthening overall oversight and ensuring ongoing compliance with federal requirements.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 529528 2022-005
    Material Weakness Repeat
  • 529529 2022-006
    Significant Deficiency
  • 529531 2022-005
    Material Weakness Repeat
  • 529532 2022-006
    Significant Deficiency
  • 529533 2022-007
    Material Weakness
  • 529534 2022-005
    Material Weakness Repeat
  • 529535 2022-006
    Significant Deficiency
  • 529536 2022-007
    Material Weakness
  • 529537 2022-005
    Material Weakness Repeat
  • 529538 2022-006
    Significant Deficiency
  • 529539 2022-007
    Material Weakness
  • 529540 2022-005
    Material Weakness Repeat
  • 529541 2022-006
    Significant Deficiency
  • 529542 2022-007
    Material Weakness
  • 529543 2022-005
    Material Weakness Repeat
  • 529544 2022-006
    Significant Deficiency
  • 529545 2022-007
    Material Weakness
  • 529546 2022-005
    Material Weakness Repeat
  • 529547 2022-006
    Significant Deficiency
  • 529548 2022-007
    Material Weakness
  • 529549 2022-005
    Material Weakness Repeat
  • 529550 2022-006
    Significant Deficiency
  • 529551 2022-007
    Material Weakness
  • 529552 2022-005
    Material Weakness Repeat
  • 529553 2022-006
    Significant Deficiency
  • 529554 2022-007
    Material Weakness
  • 529555 2022-004
    Material Weakness Repeat
  • 529556 2022-005
    Material Weakness Repeat
  • 529557 2022-006
    Significant Deficiency
  • 1105970 2022-005
    Material Weakness Repeat
  • 1105971 2022-006
    Significant Deficiency
  • 1105972 2022-007
    Material Weakness
  • 1105973 2022-005
    Material Weakness Repeat
  • 1105974 2022-006
    Significant Deficiency
  • 1105975 2022-007
    Material Weakness
  • 1105976 2022-005
    Material Weakness Repeat
  • 1105977 2022-006
    Significant Deficiency
  • 1105978 2022-007
    Material Weakness
  • 1105979 2022-005
    Material Weakness Repeat
  • 1105980 2022-006
    Significant Deficiency
  • 1105981 2022-007
    Material Weakness
  • 1105982 2022-005
    Material Weakness Repeat
  • 1105983 2022-006
    Significant Deficiency
  • 1105984 2022-007
    Material Weakness
  • 1105985 2022-005
    Material Weakness Repeat
  • 1105986 2022-006
    Significant Deficiency
  • 1105987 2022-007
    Material Weakness
  • 1105988 2022-005
    Material Weakness Repeat
  • 1105989 2022-006
    Significant Deficiency
  • 1105990 2022-007
    Material Weakness
  • 1105991 2022-005
    Material Weakness Repeat
  • 1105992 2022-006
    Significant Deficiency
  • 1105993 2022-007
    Material Weakness
  • 1105994 2022-005
    Material Weakness Repeat
  • 1105995 2022-006
    Significant Deficiency
  • 1105996 2022-007
    Material Weakness
  • 1105997 2022-004
    Material Weakness Repeat
  • 1105998 2022-005
    Material Weakness Repeat
  • 1105999 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.341 Analyses, Research and Studies to Address the Impact of Cmsõ Programs on American Indian/alaska Native (ai/an) Beneficiaries and the Health Care System Serving These Beneficiaries $835,945
93.011 National Organizations of State and Local Officials $437,983
93.421 Covid-19 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $253,538
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $169,942
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $107,186
93.933 Demonstration Projects for Indian Health $127