Finding Text
Assistance Listings number and name: 93.137 COVID-19 Community Programs to Improve Minority Health Grant Program Award number and years: 1 CPIMP211254-01-00, July 2, 2021 through June 30, 2023; Federal agency: U.S. Department of Health and Human Services Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal guidance and the County?s federal grant award terms, the County?s Health and Emergency Management Department and Finance Department did not prepare and submit timely and accurate program information to the federal grantor agency for monitoring and expense reimbursement. Specifically, the departments submitted the first 2 required quarterly reports to the federal agency in February 2022, which was 95 and 11 days later than required for the September 30, 2021 and December 31, 2021, reports, respectively. The departments also reported inaccurate information in all 4 quarterly reports they submitted. Specifically, they omitted information related to cash disbursements for the first 2 quarterly reports in the amounts of $507,363 and $359,964, respectively, resulting in cash on hand being overstated. Further, they reported inaccurate information on the final 2 quarterly reports in the amounts of $507,363 and $14,644, respectively, related to multiple line items in the reports. Effect?The departments? reporting untimely program information delayed the County?s receiving federal reimbursement for program expenditures it incurred totaling $867,327 until March 2022. Had the departments submitted the first 2 reports on time, the County could have received an initial reimbursement of $507,363 in October 2021 and a second reimbursement of $359,964 in January 2022. Also, the departments? reporting untimely and inaccurate program information negatively impacts the federal agency?s ability to effectively monitor the County?s program administration and compliance with program requirements, prevent and detect fraud, and evaluate the program?s success. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County lacked policies and procedures requiring the departments to perform and document an independent review and approval of federal program reports before submitting them to the federal agency. Although the Departments did not have policies and procedures requiring a review, they had assigned an employee to perform a review and submit the reports. However, this employee was no longer employed with the County, and therefore, the departments did not know why the reports were submitted late and the errors were not detected. Criteria?Federal agency guidance and the County?s grant award terms require the departments to submit to the federal agency quarterly program information reports to request reimbursement of program expenditures the County incurs during each quarter, no later than 30 days after each quarter?s end. Further, the guidance and award terms require the departments to complete the reports using the federal agency?s financial reporting instructions.1 Finally, federal regulation requires the County's establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County?s management should: 1. Develop and implement policies and procedures requiring the departments to: a. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. b. Submit reports on time. 2. Annually train the departments? employees who are responsible for preparing and reviewing reports regarding the information required to be gathered and documented in the County?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Health and Human Services (HHS). (2010.) Federal Financial Report Instructions. Retrieved on 4/12/2023 from https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/sf_425_instructions.pdf.