Finding Text
Finding 2023-004 Reporting
Identification of the federal program:
Federal Grantor: United States Department of Homeland Security
Pass-Through Grantor: State of Missouri, State Emergency Management Agency
Assistance Listing No.: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA)
Pass-Through Award Numbers: Project# 699963 P/W# 624; Project# 185883 P/W# 529; and Project# 150136 P/W# 171
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding 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).”
Instructions from State of Missouri, State Emergency Management Agency states “In accordance with Public Assistance Program policy, applicants, on quarterly basis, must submit a report identifying the status of each of their open/incomplete projects in each disaster for which they are applicant”.
Condition:
Timeliness and submission of the quarterly reports required by the State of Missouri could not be verified.
Cause:
Management did not retain the supporting documentation to evidence the submission of the quarterly reports.
Effect or potential effect:
Mercy Health potentially did not file the required reports with the State of Missouri on a timely basis and was not in compliance with the program reporting requirements.
Questioned costs:
None.
Context:
Mercy Health had a total of eight quarterly report submissions for the year ended June 30, 2023. We tested five of the eight quarterly reports and management did not retain supporting documentation of timely submission for any of the reports. The total federal expenditures for the program in fiscal year 2023 related to the FEMA grants was $3,383,897.
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Mercy Health should implement internal controls over the retention of supporting evidence of timely submission of the reports.
Views of Responsible Officials:
The state of Missouri requires all quarterly reports be mailed. While we did send in our quarterly reports to the state of Missouri as required, we do not have proof of submissions as we did not send by certified mail. All future quarterly reporting will be documented with an email to our state SEMA representative when we send out quarterly reports so there is documentation for our records.