Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we
examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined
did not contain sufficient evidence that a review and approval process was completed prior to
payment being processed.
Corrective Action Plan:
In response to the finding regarding insufficient internal controls over compliance for disbursements related to the Title V major program, the Nebraska Urban Indian Health Coalition (NUIHC) has previously taken several corrective actions to strengthen compliance, including:
1. Review and Revision of Policies and Procedures:
NUIHC conducted a comprehensive review of internal control policies and procedures related to disbursements. Updates were made to ensure alignment with 2 CFR §200.313(a), and clear guidelines for review and approval processes were established.
2. Staff Training and Education:
Training was provided to procurement and finance staff to ensure understanding of the revised procedures and federal compliance requirements, emphasizing the importance of proper approvals prior to disbursement.
3. Implementation of Standardized Approval Controls:
A formal approval process and checklist system were implemented to ensure all disbursements are reviewed and approved by designated authorities before payment, with documentation retained for compliance.
4. Ongoing Monitoring and Internal Reviews:
NUIHC began conducting quarterly internal compliance checks to verify adherence to updated procedures.
Update and Continuation Plan:
While these corrective actions were successfully implemented, the retirement of the former CEO temporarily stalled consistent oversight and reinforcement of these procedures. With new leadership in place, NUIHC is recommitting to the continued execution and monitoring of these corrective actions. Refresher training will be incorporated into ongoing professional development and onboarding for new staff, and quarterly internal audits will resume as scheduled.
Timeline for Implementation:
Corrective actions were initially implemented in 2024, and reinforcement activities—including staff refreshers and compliance monitoring—will continue a rolling basis starting July 2025.
Responsible Party:
Chief Financial Officer, Carlett Gregory
Anticipated Completion Date:
Ongoing; reinforcement begins July 2025