Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Health Center Program Cluster
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21
Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: CFR § 200.303 Internal controls states that 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).
Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred.
Questioned costs: None.
Context: This condition occurred in three (3) of five (5) transactions selected for testing.
Cause: Turnover in key positions within the finance department.
Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet.
Repeat Finding: Yes, prior year finding 2021-004.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control.
Views of responsible officials: There is no disagreement with this finding.