Finding Text
Finding Number: 2023-001
Finding Type: Compliance related to cash management
Information on the
Federal Program: Program Name: COVID-19 Affordable Care Act (ACA) Grants for New and
Expanded Services Under the Health Center Program (AL 93.527)
Federal Awards Project Title: FY 2023 Bridge Access Program
Award Period: September 1, 2023 - December 31, 2024
Award Number: 1 H8LCS51310-01
Views of a Responsible
Official and Corrective
Action Plan: Management agrees with the finding. The Organization will modify
procedures as appropriate to ensure grant funds are drawn in accordance
with grant terms and conditions.
Agency: U.S. Department of Health and Human Services (HHS),
Health Resources and Services Administration (HRSA)
Criteria: The Uniform Guidance §200.305(b)(1) requires that advance payments to a
non-Federal entity must be limited to the minimum amounts needed and be
timed to be in accordance with the actual, immediate cash requirements of
the non-Federal entity in carrying out the purpose of the approved program or
project. The timing and amount of advance payments must be as close as is
administratively feasible to the actual disbursements by the non-Federal
entity for direct program or project costs and the proportionate share of any
allowable indirect costs.
Condition: The Organization drew down the FY 2023 Bridge Access Program grant
funds in full upon receipt of the award in the amount of $19,507 in advance of
incurring federal expenses. The Organization identified allowable expenses
which were incurred prior to receipt of the grant award and during 2024,
management worked with HRSA to submit and obtain approval for a budget
revision, enabling the Organization to apply the funds to the pre-award costs.
Cause: Management were unaware preapproval was required to use the award for
pre-award costs.
Effect: Grant funds could be required to be returned with potential interest.
Questioned Costs: None
Repeat Finding: No
Recommendation: Management should reinforce the importance of reviewing all grant
agreement provisions, and implement a system of processes and controls for
tracking compliance with all specific grant terms and conditions.