Finding Text
Allowable Activities & Costs, Procurement Questioned Costs: $737,375
and Subrecipient Monitoring
Department of Health and Human Services
93.493 Community Funded Projects (BRIGHT)
Grant No(s): H79FG000907
Criteria: Title 2 CFR Part 200, commonly referred to as the Uniform Guidance (UG), governs the use of most federal grants. Those regulations require that costs adhere to the terms and conditions of the grant, that costs be reasonable and necessary and subjected to a system of internal controls. Purchases of goods and services under $250,000 but greater than $10,000 should be made by obtaining quotations from an adequate number of vendors, and by consolidating purchases when economical. Subrecipients should be monitored.
Condition: The City-Parish was awarded the grant for the purpose of establishing and running 5 trauma centers in Baton Rouge. However, while some of the grant costs were directed toward violence, drug abuse and counseling services, a significant portion could not be directly connected to a formally established trauma center. A significant portion of the grant funds paid for gathering type events, movie nights, fitness camps and activities of the Summer of Hope.
The services were procured among approximately 30 vendors with contracts ranging from $10,000 to $160,900 which may have resulted in price inefficiencies. No evidence was provided that price quotations were obtained for the 17 vendors with contracts exceeding $10,000. Many of these same vendors were also contracted for services through the City-Parish’s Crime/Violence prevention sub-program funded through the State and Local Fiscal Recovery grant program.
Two of the vendors were also hired for additional services not under formal contract; one to provide a movie day for $10,000 and one for $10,000 for health education and wellness promotional events.
One subrecipient was employed by the grant program and it was not properly monitored.
Finally, we noted charges from two vendors that appeared to duplicate charges made to SLFR grant program. Separate invoices submitted by each vendor for servicing family and youth showed time charges billed for the same dates and times that were previously billed to and paid by the SLFR program. The total duplicated charges total $46,045.
Universe/
Population: As substantial portion of the Program’s costs, activities, and compliance requirements were subjected to testing among the various areas of the Compliance Supplement. The questioned costs represent the known questioned costs among the various compliance areas.
Effect: The City-Parish is non-compliant with the Uniform Guidance and Program regulations. Without price comparisons, executed contracts, and appropriate monitoring of vendors and subrecipients, the City-Parish may have paid more than was necessary for the services procured.
Cause: Improper design and implementation of internal controls over grants compliance. The persons administering the program may not have been properly trained in grants management and compliance.
Recommendation: Internal controls should be established at all levels to ensure compliance. Only those trained in grants administration and Uniform Guidance should be placed in the role of program administrators.
Views of Responsible Officials:
The City-Parish transitioned the administration of the BRIGHT grant in the first quarter of 2025; therefore, we are unable to obtain some supporting documentation. The City-Parish provided documentation that a change in the project plan/scope from running five trauma centers to a variety of services based on needs and accessibility as opposed to confining them to centers was approved by the grantor agency through the programmatic reports which allowed expenses for gathering events, fitness camps, and activities for the Summer of Hope. This grant period ended September 27, 2024.
Final Auditor Comments:
Approval for the change in scope of activities should come by way of an amendment to the grant agreement signed by both parties.