Finding 563950 (2022-003)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2025-06-05
Audit: 358122

AI Summary

  • Core Issue: Draw requests were submitted before costs were incurred, violating federal guidelines.
  • Impacted Requirements: Non-compliance with 2 CFR Sections 200.305 and 200.302 regarding timely fund disbursement and documentation.
  • Recommended Follow-Up: Implement formal internal controls and ensure knowledgeable personnel review and approve draw requests.

Finding Text

FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster Criteria: In accordance with 2 CFR Section 200.305, non-federal entities must minimize the time elapsing between the transfer of funds from the federal agency or pass-through entity and disbursement by the Center for program costs and proportionate share of allowable indirect costs. Additionally, 2 CFR Section 200.302(b)(c) requires non-federal entities to establish written procedures to implement the requirements 2 CFR Section 200.305. The Federal Acquisition Regulation clause at 48 CFR Section 52.2160-7(b)(1) requires that the non-federal entity request reimbursement for only allocable, allowable, and reasonable contract costs that have already been paid or incurred. Condition: During our testing of draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.

Categories

Cash Management

Other Findings in this Audit

  • 563944 2022-003
    Material Weakness
  • 563945 2022-004
    Material Weakness
  • 563946 2022-005
    Significant Deficiency
  • 563947 2022-003
    Material Weakness
  • 563948 2022-004
    Material Weakness
  • 563949 2022-005
    Significant Deficiency
  • 563951 2022-004
    Material Weakness
  • 563952 2022-005
    Significant Deficiency
  • 563953 2022-003
    Material Weakness
  • 563954 2022-004
    Material Weakness
  • 563955 2022-005
    Significant Deficiency
  • 563956 2022-003
    Material Weakness
  • 563957 2022-004
    Material Weakness
  • 563958 2022-005
    Significant Deficiency
  • 1140386 2022-003
    Material Weakness
  • 1140387 2022-004
    Material Weakness
  • 1140388 2022-005
    Significant Deficiency
  • 1140389 2022-003
    Material Weakness
  • 1140390 2022-004
    Material Weakness
  • 1140391 2022-005
    Significant Deficiency
  • 1140392 2022-003
    Material Weakness
  • 1140393 2022-004
    Material Weakness
  • 1140394 2022-005
    Significant Deficiency
  • 1140395 2022-003
    Material Weakness
  • 1140396 2022-004
    Material Weakness
  • 1140397 2022-005
    Significant Deficiency
  • 1140398 2022-003
    Material Weakness
  • 1140399 2022-004
    Material Weakness
  • 1140400 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.48M
93.224 American Rescue Plan Act Funding for Consolidated Health Centers (hrsa) $1.15M
93.526 Covid-19 - Grants for Capital Development in Health Centers $666,000
21.027 Coronavirus State and Local Fiscal Recovery Funds $500,000
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $325,000
93.224 Covid - 19 - Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $273,915
93.011 National Organizations for State and Local Officials $159,000