FAC Explorer

Finding 968884 (2022-002)

Significant Deficiency Repeat Finding
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2024-04-05
Audit: 302752
Organization: Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund (PR)
Auditor: Aquino De Cordova LLC

AI Summary

  • Core Issue: Personnel files are often incomplete and not kept current, risking compliance with federal requirements for employee documentation.
  • Impacted Requirements: Internal controls under 2 CFR 200.303 and compensation guidelines under 2 CFR 200.430 are not being met, potentially leading to cost disallowances for federal funding.
  • Recommended Follow-Up: PRDH should review and update all personnel files to ensure compliance, including validating required documents and updating salary information.

Finding Text

Criteria 2 CFR 200.303 establish that the non-Federal entity must 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. 2 CFR 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 392413 2022-001
    Material Weakness Repeat
  • 392414 2022-001
    Material Weakness Repeat
  • 392415 2022-001
    Material Weakness Repeat
  • 392416 2022-001
    Material Weakness Repeat
  • 392417 2022-001
    Material Weakness Repeat
  • 392418 2022-001
    Material Weakness Repeat
  • 392419 2022-001
    Material Weakness Repeat
  • 392420 2022-001
    Material Weakness Repeat
  • 392421 2022-001
    Material Weakness Repeat
  • 392422 2022-001
    Material Weakness Repeat
  • 392423 2022-001
    Material Weakness Repeat
  • 392424 2022-001
    Material Weakness Repeat
  • 392425 2022-001
    Material Weakness Repeat
  • 392426 2022-001
    Material Weakness Repeat
  • 392427 2022-001
    Material Weakness Repeat
  • 392428 2022-002
    Significant Deficiency Repeat
  • 392429 2022-002
    Significant Deficiency Repeat
  • 392430 2022-002
    Significant Deficiency Repeat
  • 392431 2022-002
    Significant Deficiency Repeat
  • 392432 2022-002
    Significant Deficiency Repeat
  • 392433 2022-002
    Significant Deficiency Repeat
  • 392434 2022-002
    Significant Deficiency Repeat
  • 392435 2022-002
    Significant Deficiency Repeat
  • 392436 2022-002
    Significant Deficiency Repeat
  • 392437 2022-002
    Significant Deficiency Repeat
  • 392438 2022-002
    Significant Deficiency Repeat
  • 392439 2022-002
    Significant Deficiency Repeat
  • 392440 2022-002
    Significant Deficiency Repeat
  • 392441 2022-002
    Significant Deficiency Repeat
  • 392442 2022-002
    Significant Deficiency Repeat
  • 392443 2022-003
    Significant Deficiency
  • 392444 2022-003
    Significant Deficiency
  • 392445 2022-004
    Material Weakness Repeat
  • 392446 2022-005
    Material Weakness Repeat
  • 392447 2022-006
    Material Weakness Repeat
  • 392448 2022-006
    Material Weakness Repeat
  • 392449 2022-006
    Material Weakness Repeat
  • 392450 2022-006
    Material Weakness Repeat
  • 392451 2022-007
    Material Weakness
  • 392452 2022-007
    Material Weakness
  • 392453 2022-007
    Material Weakness
  • 392454 2022-007
    Material Weakness
  • 392455 2022-008
    Material Weakness
  • 392456 2022-008
    Material Weakness
  • 392457 2022-008
    Material Weakness
  • 392458 2022-008
    Material Weakness
  • 392459 2022-008
    Material Weakness
  • 392460 2022-008
    Material Weakness
  • 392461 2022-008
    Material Weakness
  • 392462 2022-008
    Material Weakness
  • 392463 2022-008
    Material Weakness
  • 392464 2022-008
    Material Weakness
  • 392465 2022-008
    Material Weakness
  • 392466 2022-008
    Material Weakness
  • 392467 2022-008
    Material Weakness
  • 392468 2022-008
    Material Weakness
  • 392469 2022-008
    Material Weakness
  • 968855 2022-001
    Material Weakness Repeat
  • 968856 2022-001
    Material Weakness Repeat
  • 968857 2022-001
    Material Weakness Repeat
  • 968858 2022-001
    Material Weakness Repeat
  • 968859 2022-001
    Material Weakness Repeat
  • 968860 2022-001
    Material Weakness Repeat
  • 968861 2022-001
    Material Weakness Repeat
  • 968862 2022-001
    Material Weakness Repeat
  • 968863 2022-001
    Material Weakness Repeat
  • 968864 2022-001
    Material Weakness Repeat
  • 968865 2022-001
    Material Weakness Repeat
  • 968866 2022-001
    Material Weakness Repeat
  • 968867 2022-001
    Material Weakness Repeat
  • 968868 2022-001
    Material Weakness Repeat
  • 968869 2022-001
    Material Weakness Repeat
  • 968870 2022-002
    Significant Deficiency Repeat
  • 968871 2022-002
    Significant Deficiency Repeat
  • 968872 2022-002
    Significant Deficiency Repeat
  • 968873 2022-002
    Significant Deficiency Repeat
  • 968874 2022-002
    Significant Deficiency Repeat
  • 968875 2022-002
    Significant Deficiency Repeat
  • 968876 2022-002
    Significant Deficiency Repeat
  • 968877 2022-002
    Significant Deficiency Repeat
  • 968878 2022-002
    Significant Deficiency Repeat
  • 968879 2022-002
    Significant Deficiency Repeat
  • 968880 2022-002
    Significant Deficiency Repeat
  • 968881 2022-002
    Significant Deficiency Repeat
  • 968882 2022-002
    Significant Deficiency Repeat
  • 968883 2022-002
    Significant Deficiency Repeat
  • 968885 2022-003
    Significant Deficiency
  • 968886 2022-003
    Significant Deficiency
  • 968887 2022-004
    Material Weakness Repeat
  • 968888 2022-005
    Material Weakness Repeat
  • 968889 2022-006
    Material Weakness Repeat
  • 968890 2022-006
    Material Weakness Repeat
  • 968891 2022-006
    Material Weakness Repeat
  • 968892 2022-006
    Material Weakness Repeat
  • 968893 2022-007
    Material Weakness
  • 968894 2022-007
    Material Weakness
  • 968895 2022-007
    Material Weakness
  • 968896 2022-007
    Material Weakness
  • 968897 2022-008
    Material Weakness
  • 968898 2022-008
    Material Weakness
  • 968899 2022-008
    Material Weakness
  • 968900 2022-008
    Material Weakness
  • 968901 2022-008
    Material Weakness
  • 968902 2022-008
    Material Weakness
  • 968903 2022-008
    Material Weakness
  • 968904 2022-008
    Material Weakness
  • 968905 2022-008
    Material Weakness
  • 968906 2022-008
    Material Weakness
  • 968907 2022-008
    Material Weakness
  • 968908 2022-008
    Material Weakness
  • 968909 2022-008
    Material Weakness
  • 968910 2022-008
    Material Weakness
  • 968911 2022-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $2.97B
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $150.77M
93.767 Children's Health Insurance Program $111.87M
93.917 Hiv Care Formula Grants $27.92M
93.994 Maternal and Child Health Services Block Grant to the States $13.34M
10.578 Wic Grants to States (wgs) $6.36M
93.069 Public Health Emergency Preparedness $6.16M
93.966 The Zika Health Care Services Program $4.32M
93.889 National Bioterrorism Hospital Preparedness Program $3.13M
84.181 Special Education-Grants for Infants and Families $2.86M
93.268 Immunization Cooperative Agreements $2.75M
93.991 Preventive Health and Health Services Block Grant $2.41M
93.110 Maternal and Child Health Federal Consolidated Programs $1.84M
93.136 Injury Prevention and Control Research and State and Community Based Programs $1.83M
93.235 Affordable Care Act (aca) Abstinence Education Program $1.59M
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $1.44M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.39M
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $1.28M
93.255 Children's Hospitals Graduate Medical Education Payment Program $1.04M
93.377 Prevention and Control of Chronic Disease and Associated Risk Factors in the U.s. Affiliated Pacific Islands, U.s. Virgin Islands, and P. R. (b) $902,678
93.777 State Survey and Certification of Health Care Providers and Suppliers (title Xviii) Medicare $876,845
66.468 Capitalization Grants for Drinking Water State Revolving Funds $792,740
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $727,037
66.432 State Public Water System Supervision $608,799
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $371,524
93.070 Environmental Public Health and Emergency Response $354,863
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $349,580
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $257,928
93.251 Early Hearing Detection and Intervention $253,036
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $234,825
93.236 Grants to States to Support Oral Health Workforce Activities $227,330
93.817 Hospital Preparedness Program (hpp) Ebola Preparedness and Response Activities $216,975
93.314 Early Hearing Detection and Intervention Information System (ehdi-Is) Surveillance Program $170,942
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs $160,918
20.607 Alcohol Open Container Requirements $154,751
93.336 Behavioral Risk Factor Surveillance System $153,793
93.130 Cooperative Agreements to States/territories for the Coordination and Development of Primary Care Offices $138,398
93.940 Hiv Prevention Activities_health Department Based $97,967
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $84,067
93.270 Adult Viral Hepatitis Prevention and Control $65,865
14.241 Housing Opportunities for Persons with Aids $58,672
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $31,870
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $22,259
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $18,302
93.745 Pphf: Health Care Surveillance/health Statistics Ð Surveillance Program Announcement: Behavioral Risk Factor Surveillance System Financed in Part by Prevention and Public Health Fund $15,511
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $9,250
93.387 National and State Tobacco Control Program (b) $6,982
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $3,492
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $-11,111