Finding 551136 (2024-001)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The Agency deviated from established internal control policies, including unauthorized changes to work hours and improper credit card usage.
  • Impacted Requirements: Compliance with 2 CFR 200.303 was compromised, risking noncompliance with federal regulations and the terms of federal awards.
  • Recommended Follow-Up: Implement and enforce procedures to ensure adherence to Board-approved internal controls and policies.

Finding Text

2024-001: Internal Controls over Compliance for Allowable Costs Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Missouri Department of Health and Senior Services Federal Assistance Listing Number: 93.044/93.045/93.053 Program Title: Aging Cluster Pass-through Entity Identifying Number: ERS1052004 Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.303 states, “The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: During our audit, we noted instances of deviations from documented internal control policies and management override of internal controls: • The former Executive Director implemented a 36-hour work week policy by closing the administrative offices at noon every Friday effective January 1, 2024. However, the Agency’s Personnel Policies and Administrative Procedures, Guidelines and Benefits manual was not updated to reflect this change from a 40-hour to a 36-hour work week. Employees recorded 4 hours of “Other Paid Leave” on their timesheets every Friday for the time the offices were closed. We also noted that employees recorded “Other Paid Leave” for the Friday after Thanksgiving during the fiscal year. This was not one of the officially recognized paid holidays in the adopted policy manual. • The Agency did not follow the prescribed procedures for reviewing and paying credit card charges during the year. The Agency’s Accounting Manual calls for all receipts for credit card charges to be submitted to the CFO to verify the charges on the monthly statement prior to paying the credit card bill. However, during the fiscal year there were instances noted where the former Executive Director made credit card payments online, circumventing the Agency’s accounts payable process. The Accounting Manual also prohibits unauthorized charges to the company credit card, such as personal expenditures. We noted $3,171 of personal charges made by the former Executive Director to the company credit card in the general ledger. These charges were recorded as prepaid expenses in the accounting system and therefore were not charged to federal awards. The former CFO would reduce the Executive Director’s paycheck to reimburse the company for any personal charges noted on the credit card. Cause: The November 2023 Board minutes mention the Executive Director’s plan for going to a 36-hour work week effective January 1, 2024, however, the Board did not approve the policy at that time and the Agency’s personnel policy manual was not updated and approved by the Board. The June 2024 Board minutes reflect an approved motion by the Board to approve the 36-hour work week and the policy manual was updated to reflect the 36-hour work week in October 2024. The revised policy manual also reflects 14 paid holidays, which was increased from the 11 paid holidays noted in the prior version of the manual. During the fiscal year, there was management override of the prescribed internal controls regarding charges to the company credit card. Effect: Internal controls over compliance that can prevent and detect noncompliance with federal statutes, regulations and the terms and conditions of the Agency’s federal awards are necessary to ensure that only allowable and authorized expenses are charged to federal awards. Recommendation: We recommend that the Agency implement procedures to ensure that the prescribed internal controls, policies and procedures officially adopted by the Board of Directors are implemented and consistently followed.

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Other Findings in this Audit

  • 551134 2024-001
    Significant Deficiency
  • 551135 2024-001
    Significant Deficiency
  • 551137 2024-001
    Significant Deficiency
  • 551138 2024-001
    Significant Deficiency
  • 1127576 2024-001
    Significant Deficiency
  • 1127577 2024-001
    Significant Deficiency
  • 1127578 2024-001
    Significant Deficiency
  • 1127579 2024-001
    Significant Deficiency
  • 1127580 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.053 Nutrition Services Incentive Program $356,291
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $335,226
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $326,830
93.667 Social Services Block Grant $125,043
93.052 National Family Caregiver Support, Title Iii, Part E $94,623
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $42,183
93.747 Elder Abuse Prevention Interventions Program $40,219
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $35,000
93.071 Medicare Enrollment Assistance Program $33,405
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $18,835
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $373