Finding Text
2022-003 Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 2 TIN#237224698 Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Organization?s final eligible expenditure listing identified as eligible and claimed under the Provider Relief Fund program was not reviewed and approved by a separate individual outside of the preparer. In addition, the Organization?s special report submitted to the Department of Health and Human Services for Period 2 TIN #237224698 was not reviewed and approved by a separate individual outside of the preparer. There were also expenses within that listing and also included on the submitted report that were unallowable. Cause: The Organization did not have an adequate internal control policy in place to ensure the allowability of all costs claimed under the federal program due to clerical inaccuracies. The Organization also did not have an internal control process in place to ensure a secondary review and approval of the eligible expenditure listing was documented. In addition, the review and approval of the report submitted to the Department of Health and Human Services for Period 2 was not performed by someone other than the preparer of the report. Effect: Without a secondary review and approval, there is a possibility that ineligible expenditures may be claimed under the program and the report may not be accurately completed. Questioned Costs: None over $25,000. Context: A nonstatistical sample of 65 ($71,005) out of over 250 expenses ($644,135) were tested for activities allowed or unallowed and allowable costs/cost principles. Key line items were tested on the Period 2 Department of Health and Human Services special report. Repeat Finding from Prior Years: No Recommendation: We recommend that the Organization enhance internal control policies to ensure the allowability of all costs claimed under the federal program. We also recommend the Organization implement a control process which includes a secondary review and approval of the summarized final expenditure listing used to claim the allowable costs under the federal program and a secondary review and approval of required reports to be submitted to the federal agency Views of Responsible Officials: Management agrees with the finding.