Finding Text
2022-002 Update Documented Policies and Procedures Over Federal Awards
Federal Program Information
Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention
Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
Assistance Listing Number(s): 93.136, 93.391
Award Year: 2022
Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring
Type of Finding
Compliance
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement
OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Employee travel
• Cash management
• Procurement
• Conflicts of interest
• Subrecipient monitoring and management
Condition and Context
Although the Organization has written policies and procedures related to federal awards, certain areas are not fully in compliance with the requirements of the Uniform Guidance.
Cause
The Organization has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance.
Effect or Potential Effect
Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature.
Recommendation
The Organization should address the weakness noted above and update its policies and procedures related to federal awards in order to comply with the Uniform Guidance. Specific attention should be given to subrecipient monitoring, including required information in subrecipient agreements, references to Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls.
Views of Responsible Official
Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.