Finding Text
Assistance Listing, Federal Agency, and Program Name - 93.918, U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA), Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease
Federal Award Identification Number and Year - H76HA00107, 2022
Pass-through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal controls 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 the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Framework, issued by the Committee of Sponoring Organizations of the Treadwy Commission (COSO).
Condition - Management did not have controls in place to ensure required reporting submissions to HRSA were reviewed for accuracy, completeness, and compliance with the terms and conditions prescribed by the funding agency by an individual other than the indvidual preparing the report.
Questioned Costs - None
Identification of How Questioned Costs Were Computed -Not applicable, as no questioned costs were identified.
Context - During testing of the Institute's annual submission of its Federal Financial Report (FFR or SF-425), we noted the individual compiling the information also prepared the report without a secondary level of review.
Cause and Effect - Though some elements of the report automatically populate from HRSA's Payment Management System, other key pieces of information are manually added to the report from underlying ledgers or other reports. Without a level of review in advance of the submission, information in the report could be materially mistated or out of compliance with HRSA's reporting requirements.
Recommendation - We recommend management implement a level of review in advance of the report submission to ensure individuals who prepare reports are different from those who review and file the reports and to ensure reports are prepared in compliance with funding agency requirements.
Views of Responsible Officials and Corrective Action Plan - Management concurs with the recommendation and will review the appropriate guidance and implement enhanced procedures for including secondary levels of review.