Finding Text
2022-001? Allowable Costs and Activities Federal agency: U.S. Department of Health and Human Services Federal program title: Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Reporting Period 2 for Funds Received July 1, 2020 to December 31, 2020, Used through December 31, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or specific requirement: 2 CFR 200.303(a) established 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. Makom did not have a formal policy for the provision of overnight stipend pay to eligible employees to document related controls and procedures in order to comply with federal awards. The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. Condition: The Jewish Foundation for Group Homes, Inc. (d.b.a. Makom) did not have documented policies and procedures for determining and providing overnight stipend pay. Such pay was tracked in detail and reviewed, with formal approval documented, but there was not a formal documented policy to ensure practical adherence in order to comply with federal awards. Questioned Costs: None Context: Makom maintained detailed records of federal funds applications for tracking and required reporting purposes. There was not, however, formal documentation of the Organization?s overnight stipend pay policy to comply with federal awards. Cause: Makom had not previously received federal awards in an amount sufficient to require an audit under Uniform Guidance. Therefore, more formal controls and procedures around the use of federal awards had not been in place. The Provider Relief Fund amounts received in response to the COVID-19 pandemic were an unexpected occurrence. As the relief funds were distributed to Makom, the focus of management and governance was on responding to the pandemic, and tracking use of related relief funds, and not necessarily incorporating formal policies and procedures. Effect: Without formal policies and procedures in place, there is a greater risk of inconsistent application of overnight stipend pay that could result in improper use of federal funds or misstatement in required federal reporting. Repeat finding: No Recommendation: We recommend that management develop and document clear and consistent policies and procedures for determining overnight stipend pay to improve the controls surrounding it and comply with federal awards. Views of responsible officials: There is no disagreement with the audit finding.