Finding Text
2024 – 001 Period of Performance
Federal Agency: U.S. Department of Health and Human Services
Federal Program: Consolidated Health Centers Grant
AL Number: 93.224 & 93.527
Award Period: 1/1/24 - 12/31/24
Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance
Criteria or Specific Requirement
According to § 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. According to 2 CFR 200.1 Period of Performance is defined as the total
estimated time interval between the start of an initial Federal award and the planned end date, which
may include one or more funded portions, or budget periods.
Condition and Context
The Organization began allocating direct salaries and benefits prior to the awards period of performance
start date. The Organization allocated expenditures based on the payroll paid date, rather than the date
the payroll was incurred. Total direct salaries and benefits allocated to the grant prior to the period of
performance start date was $21,049.
Effect
Potential that costs will be charged to the grant outside of the period of performance.
Questioned Costs
$21,049
Cause
The Organization allocated payroll expenditures based on the paid date, rather than the incurred date.
Recommendation
We recommend the Organization update their method of allocating expenditures to federal awards based
on the incurred date, rather than paid date.Views of Responsible Officials
The Organization corrected the period of performance finding prior to the 2024 audit being completed
and feel this was an isolated incident. The issue was caused by staff turnover in 2024, and new staff
have been properly trained to review all grants to ensure compliance with all grant regulations. This grant
can be used for staffing costs and upon identification of this issue we have corrected the allocations to
the prior grant periods. Going forward, the Organization has implemented controls to ensure that all staff
are being trained to ensure they are following grant guidelines.