Finding Text
Finding 2022-003 ? L. Reporting Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain supporting documentation over its review and approval of quarterly progress reports required to be submitted to FEMA during the period January 1, 2022 through June 30, 2022. While management had a process to prepare and review reports submitted under the FEMA program, sufficient documentation was not retained to support the process. In addition, for certain quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, the review was completed after submission of the quarterly progress report to FEMA. Cause: Internal controls over the review and approval of quarterly progress reports submitted to FEMA were not implemented until the third quarter of fiscal year 2022. In addition, internal controls implemented in the third quarter of fiscal year 2022 were not operating effectively. Effect or potential effect: Reports submitted to FEMA could be inaccurate or incomplete. Questioned costs: None. Context: Of the 16 quarterly progress reports submitted to FEMA during the year ended December 31, 2022, we were unable to test controls over the eight quarterly progress reports submitted during the period January 1, 2022 through June 30, 2022. We tested four of eight quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, and noted that for all four, the review was completed the day after the quarterly progress reports were submitted to FEMA. Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should follow its internal control implemented on July 1, 2022, over the timely review and approval of reports for accuracy and completeness and ensure the review is performed prior to the reports being submitted. Views of responsible officials: Management agrees with the finding and will implement controls and documentation over the timely review and approval of quarterly progress reports submitted to FEMA.