Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 4 C14CS39926-01-06, September 1, 2020 – November 30, 2023
Award No. 4 H8FCS40544-01-03, April 1, 2021 – March 31, 2024
Award No. 1 H2ECS45559-01-01, May 1, 2022 – April 30, 2023
Award No. 6 H8HCS44994-02-02, September 1, 2022 – August 31, 2023
Award No. 4 H8GCS48199-01-01, December 1, 2022 – December 31, 2023
Award No. 6 H2ECS45559-02-03, May 1, 2023 – April 30, 2025
Award No. 1 H8LCS51638-01-00, September 1, 2023 – August 31, 2024
Award No. 5 H8HCS44994-03-00, September 1, 2023 – August 31, 2024
Award No. 6 H2ECS50103-01-02, September 1, 2023 – August 31, 2024
Criteria or Specific Requirement – Activities Allowed or Unallowed and Allowable Costs/Cost Principles (45 CFR 75.403 and 45 CR 75.421)
Condition – Advertising costs unrelated to the performance of the Federal award were charged to grant.
Questioned Costs – $1,685. Questioned costs were determined as the value of errors found in the sample of direct, non-payroll grant expenditures. Questioned costs by federal award identification number are:
• Assistance Listing No. 93.224 Award No. 6 H8HCS44994-02-02 – $1,685
Context – A sample of 25 expenditures were tested out of a population of 289 direct, non-payroll grant expenditures. Samples were not, and were not intended to be, statistically valid. A portion of two expenditures included in the sample were charged to the wrong grant. Advertising costs charged to the grant were not necessary for the performance of the Federal award. Additionally, the Organization’s internal controls over tracking grant expenditures includes both tracking within the general ledger system and on manual spreadsheets, which are utilized to support grant drawdowns. Inconsistencies between the two tracking systems were identified through both a reconciliation of Federal awards received and expended within the general ledger system and sampling referenced above.
Effect – The Organization charged unallowable advertising costs to the grant.
Cause – The Organization’s accounts payable process did not identify the difference in allowability of costs when invoices included advertising services for multiple grants. The Organization’s internal control over compliance involves duplicative effort tracking grant expenditures and routine allocation of expenditures after-the-fact to correct the assignment of grant segments to expenses in the general ledger system.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – The Organization should implement a process of obtaining approval of the grant segment assignment upon receipt of each invoice by an individual with knowledge of compliance requirements and the HRSA-approved grant budget, but distinct from the requestor of the expense. With increased oversight of grant segment assignments at the time of recording grant expenditures, the Organization should eliminate manual tracking of grant expenditures via spreadsheet and reduce the risk of double-dipping due to prevalence of manual journal entries to assign grant segments to expenditures.
Views of responsible officials and planned corrective actions – Education regarding coding of invoices to grants and only picking up current balances due has been done to both grant project directors and accounts payable. Going forward, we will ensure no balances are duplicated and grant directors can ensure the balances charged to their grants as appropriate and approved.
Recommendation – The Organization should implement a process of obtaining approval of the grant segment assignment upon receipt of each invoice by an individual with knowledge of compliance requirements and the HRSA-approved grant budget, but distinct from the requestor of the expense. With increased oversight of grant segment assignments at the time of recording grant expenditures, the Organization should eliminate manual tracking of grant expenditures via spreadsheet and reduce the risk of double-dipping due to prevalence of manual journal entries to assign grant segments to expenditures.
Views of responsible officials and planned corrective actions –