Finding 569698 (2024-003)

Significant Deficiency Repeat Finding
Requirement
F
Questioned Costs
-
Year
2024
Accepted
2025-06-30

AI Summary

  • Core Issue: The Coalition lacks proper controls to manage and track equipment purchased with federal funds, leading to potential misplacement or theft.
  • Impacted Requirements: Non-compliance with FAR Contract Clause 52.245-1, which mandates procedures for managing government property.
  • Recommended Follow-Up: Implement necessary control policies, train staff on these procedures, and conduct an annual inventory of federally funded equipment.

Finding Text

Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002) Significant Deficiency Criteria: In accordance with Federal Acquisition Regulation (FAR) Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of Department of Health and Human Services (DHHS) Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)." Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed. Questioned Costs: None Cause: The Coalition does not have sufficiently established control policies and procedures to identify, mark, record, or maintain equipment. The Coalition also does not have sufficiently established control policies for an annual inventory. Effect: The Coalition does not have the ability to discern "Government Property" from other property. The Coalition at any time is unaware if "Government Property" is misplaced or stolen. Recommendation: We recommend the Coalition becomes familiar with requirements of FAR Contact Clause 52.245-1 "Government Property" and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition schedule and perform an annual inventory of property being purchased with federal funds. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.

Corrective Action Plan

Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002) Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed. Corrective Action Plan – Finding 2024-003 Corrective Action: The Nebraska Urban Indian Health Coalition (NUIHC), in conjunction with our IT provider, has implemented a tracking system to support effective management of computer and other equipment purchased with federal funds. This includes maintaining an active equipment list and regularly updating clinic inventory on a quarterly basis for both clinic sites. Additionally, other organizational equipment is tracked using our depreciation schedule and internal records for assets that do not meet fixed asset thresholds. Inventory identification and tagging procedures are currently underway, with the goal of ensuring all equipment is properly labeled with a unique identifier and clearly marked to reflect Title V or other applicable funding sources. To further strengthen our internal controls and ensure full compliance with 2 CFR §200.313, NUIHC will take the following steps: 1. Development of Written Procedures: Comprehensive written procedures will be finalized and implemented to cover the maintenance, repair, protection, preservation, control, and accountability of all equipment purchased with federal funds. 2. Training for Staff: Additional training will be provided to all relevant staff responsible for equipment procurement, inventory tracking, and maintenance. This training will focus on the importance of proper identification, documentation, and adherence to federal equipment management standards. 3. Ongoing Monitoring: NUIHC will continue quarterly updates of clinic inventories and include periodic spot checks to verify the accuracy of records and physical inventory. Timeline for Implementation: • Finalization of written procedures: By August 31, 2025 • Completion of equipment identification and labeling: By September 30, 2025 • Staff training: Starting August 2025 and incorporated into annual compliance training Responsible Party: Chief Financial Officer, Carlett Gregory Anticipated Completion Date: September 30, 2025

Categories

Equipment & Real Property Management

Other Findings in this Audit

  • 569696 2024-002
    Material Weakness Repeat
  • 569697 2024-002
    Material Weakness Repeat
  • 569699 2024-003
    Significant Deficiency Repeat
  • 569700 2024-004
    - Repeat
  • 569701 2024-004
    - Repeat
  • 569702 2024-005
    - Repeat
  • 569703 2024-005
    - Repeat
  • 1146138 2024-002
    Material Weakness Repeat
  • 1146139 2024-002
    Material Weakness Repeat
  • 1146140 2024-003
    Significant Deficiency Repeat
  • 1146141 2024-003
    Significant Deficiency Repeat
  • 1146142 2024-004
    - Repeat
  • 1146143 2024-004
    - Repeat
  • 1146144 2024-005
    - Repeat
  • 1146145 2024-005
    - Repeat

Programs in Audit

ALN Program Name Expenditures
93.U01 Title V, Urban Health Services $922,971
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $302,599
93.193 Urban Indian Health Services $218,563
16.841 Voca Tribal Victim Services Set-Aside Program $136,178
93.800 Organized Approaches to Increase Colorectal Cancer Screening $82,270
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $28,730
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $19,679