Finding 573665 (2024-002)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
$1
Year
2024
Accepted
2025-08-14
Audit: 364306
Organization: Trilogy, Inc. (IL)

AI Summary

  • Core Issue: Costs totaling $7,311 were charged to the federal grant outside the approved budget period.
  • Impacted Requirements: Compliance with 2 CFR sections 200.308, 200.309, and 200.403(h) regarding allowable costs.
  • Recommended Follow-Up: Revise cost allocation processes to include more thorough reviews to prevent unallowable costs from being charged to federal grants.

Finding Text

Federal Agency: Department of Health and Human Services Federal program title: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Pass-Through Agency: Illinois Department of Human Services Pass-Through Number: 45CCB03514; 45CCB04278; 45CCB00648 Award Period: 07/01/2023 – 06/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition: Costs outside of the period of performance were charged to the grant. Questioned Costs: $7,311 Context: Four (4) of the twenty (20) transactions selected for testing. Cause: Oversight. Effect: The Organization may allocate unallowable costs to the federal grant. Repeat Finding: Yes, prior year finding number was 2023-004 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriately excluded from the federal grant. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: Trilogy will conduct a thorough review of our current cost allocation procedures to identify gaps related to the timing and eligibility of expenses. Based on this review, we will revise our process to ensure that only allowable costs incurred within the grant’s period of performance are charged. A multi-tiered review process will be established, to verify expense timing and relevance and to confirm compliance with grant terms. Staff will review descriptions and flag transactions that fall outside the grant’s period of performance. These controls will prevent such costs from being allocated unless properly justified and approved. Staff involved in grant management will receive updated training on federal cost principles, including the importance of period-of-performance compliance. Written guidance will be distributed to reinforce expectations. Name(s) of the contact person(s) responsible for corrective action: Shunita Rhodes & Hagar Buster Planned completion date for corrective action plan: July 2025

Categories

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 573664 2024-001
    Material Weakness Repeat
  • 573666 2024-003
    Significant Deficiency Repeat
  • 573667 2024-004
    Significant Deficiency
  • 1150106 2024-001
    Material Weakness Repeat
  • 1150107 2024-002
    Material Weakness Repeat
  • 1150108 2024-003
    Significant Deficiency Repeat
  • 1150109 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.958 Block Grants for Community Mental Health Services $547,579
93.959 Block Grants for Prevention and Treatment of Substance Abuse $319,527
14.267 Continuum of Care Program $295,420
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $92,383
93.150 Projects for Assistance in Transition From Homelessness (path) $90,380
14.218 Community Development Block Grants/entitlement Grants $71,147
21.027 Coronavirus State and Local Fiscal Recovery Funds $58,452