EIN: 237156945
UEI: MLZJKNDAE8J3
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 24, 2022 (1432 days ago).
What is a management decision? →Item 2021-002 ? Internal Controls over Reporting Material Weakness Federal Program ? Urban Indian Health Services CFDA Number ? 93.228 Federal Award Numbers ? HHSI24620180004C, 75H7711211C00001 Federal Award Year ? June 30, 2021 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Not Applicable Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards 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. Condition/context: Amounts in grant reports did not reconcile to the general ledger and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: General ledger accounts were adjusted after reports were filed causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2020-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports. Evaluate if revised reports need to be filed with the appropriate agencies. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2021-002 ? Internal Controls over Reporting Material Weakness Federal Program ? Urban Indian Health Services CFDA Number ? 93.228 Federal Award Numbers ? HHSI24620180004C, 75H7711211C00001 Federal Award Year ? June 30, 2021 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Not Applicable Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards 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. Condition/context: Amounts in grant reports did not reconcile to the general ledger and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: General ledger accounts were adjusted after reports were filed causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2020-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports. Evaluate if revised reports need to be filed with the appropriate agencies. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Finding: Item 2021-002 ? Internal Controls over Reporting Management?s View ? We concur with the finding. General Ledger accounts must be reconciled to Federal Awards and subsequently to reporting that is submitted to the Federal Agency. Corrective Action Plan (CAP) ? The organization has defined policy and procedures that directs the closure of the ledgers no later than the 15th day of any given month. This process includes verification that all Federal PMS Drawn Downs have been recorded in the Ledgers and that all funds transferred between accounts are reconciled in a timely manner. Assurance that all bank accounts are completely reconciled is a key component in the process and will need to be completed by the 15th of the month. The CFO for the organization has completed training with the Senior Staff Accountant and Staff Accountant on the process and will work directly with him to ensure that the UITCT Accounting Department performs a full reconciliation of all accounts with assurance that said reconciliation will be maintained on a consistent basis. The Director of Operations is responsible for maintaining a calendar of all required filing due dates and ensures these reports are being completed/filed on time. Our current accounting system provides the required information needed to file all reporting requirements by a funding agency. This information is attached to all reports and stored in file within the CFO?s office. This backup is available for review at any point in time by internal and external auditors. We have accomplished this task and will work diligently to ensure its continued integrity. As an additional measure to ensure compliance, the CEO now reviews and electronically signs bank reconciliations monthly.
2020-005
Finding: Item 2021-003 ? Procurement: Procurement Policy Federal Program ? Urban Indian Health Services CFDA Number ? 93.228 Federal Award Numbers ? HHSI24620180004C, 75H7711211C00001 Federal Award Year ? June 30, 2021 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Not Applicable Criteria: The Organization is required to follow 2 CFR ?200.318 General procurement standards through ?200.326 Contract provisions. Condition/context: The Organization's procurement policy was updated April 2020 to comply with Uniform Grant Guidance (UGG); however, the Organization did not fully implement the policy during the year. Cause: The Organization has not updated its contracts with significant vendors in order to comply with its own internal policies and Suspension and Debarment rules under UGG. Effect: The Organization may not follow federally mandated procurement procedures and could use a suspended or debarred contractor. Questioned cost: Not applicable. Repeat finding: This is not a repeat finding. Recommendation: Management should implement all components of its procurement policy to comply with Suspension and Debarment rules in UGG. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2021-003 ? Procurement: Procurement Policy Federal Program ? Urban Indian Health Services CFDA Number ? 93.228 Federal Award Numbers ? HHSI24620180004C, 75H7711211C00001 Federal Award Year ? June 30, 2021 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Not Applicable Criteria: The Organization is required to follow 2 CFR ?200.318 General procurement standards through ?200.326 Contract provisions. Condition/context: The Organization's procurement policy was updated April 2020 to comply with Uniform Grant Guidance (UGG); however, the Organization did not fully implement the policy during the year. Cause: The Organization has not updated its contracts with significant vendors in order to comply with its own internal policies and Suspension and Debarment rules under UGG. Effect: The Organization may not follow federally mandated procurement procedures and could use a suspended or debarred contractor. Questioned cost: Not applicable. Repeat finding: This is not a repeat finding. Recommendation: Management should implement all components of its procurement policy to comply with Suspension and Debarment rules in UGG. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Finding: Item 2021-003 ? Procurement: Procurement Policy Management?s View ? We concur with the finding. Per Uniform Guidance, all vendors need to be verified as to whether or not they have been debarred from working with federal agencies. Corrective Action Plan (CAP) ? Going forward all vendors will be looked up on the SAM website to verify whether or they have been debarred. The responsibility for this task will lie with the Executive Director, Omer Tamir.
FAC accepted this audit on March 21, 2021 — management decision was due September 21, 2021.
Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition/context: Dollar amounts in the grant reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: as reported in finding 2020-001, certain general ledger accounts were reconciled after year-end, causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: n/a Repeat finding: Finding is a repeat of finding 2019-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports.
Show full finding ▾Hide full finding ▴Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition/context: Dollar amounts in the grant reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: as reported in finding 2020-001, certain general ledger accounts were reconciled after year-end, causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: n/a Repeat finding: Finding is a repeat of finding 2019-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports.
Finding: Item 2020-005 ? Internal Controls over Federal Programs Management?s View ? We concur with the finding. General Ledger accounts must be reconciled to Federal Awards and subsequently to reporting that is submitted to the Federal Agency. Corrective Action Plan (CAP) ? The organization has defined policy and procedures that directs the closure of the ledgers no later than the 15th day of any given month. This process includes verification that all Federal PMS Drawn Downs have been recorded in the Ledgers, that all funds transferred between accounts are reconciled, and that accruals are recorded in a timely manner. Assurance that all bank accounts are completely reconciled is a key component in the process. The Controller for the organization has completed training with the Director of Accounting on the process and will work directly with him to ensure that the UITCT Accounting Department performs a full reconciliation of all accounts with assurance that said reconciliation will be maintained on a consistent basis. Our current accounting system provides the required information needed to file all reporting requirements by a funding agency. This information is attached to all reports and stored in file within the Controller?s office. This backup is available for review at any point in time by internal and external auditors. We have accomplished this task and will work diligently to ensure its continued integrity.
2019-005
Criteria: The grant agreements for Urban Indian Health Services requires certain reports to be filed within 45 days of quarter-end, and an annual inventory to be submitted by December 31 to the IHS Property Administrator. Condition/context: There were several occurrences of reports not being timely filed or not being filed. The annual inventory was not submitted by December 31 to the IHS Property Administrator. Form SF-425 for the Urban Indian Health Services grant were not submitted quarterly. Additionally, dollar amounts in the reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: The Center does not have internal controls in place to monitor report due dates. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: N/a Repeat finding: Finding is a repeat of finding 2019-006 in the immediately prior audit. Recommendation: Management should maintain a master summary schedule that identifies the responsible parties and details all report due dates.
Show full finding ▾Hide full finding ▴Criteria: The grant agreements for Urban Indian Health Services requires certain reports to be filed within 45 days of quarter-end, and an annual inventory to be submitted by December 31 to the IHS Property Administrator. Condition/context: There were several occurrences of reports not being timely filed or not being filed. The annual inventory was not submitted by December 31 to the IHS Property Administrator. Form SF-425 for the Urban Indian Health Services grant were not submitted quarterly. Additionally, dollar amounts in the reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: The Center does not have internal controls in place to monitor report due dates. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: N/a Repeat finding: Finding is a repeat of finding 2019-006 in the immediately prior audit. Recommendation: Management should maintain a master summary schedule that identifies the responsible parties and details all report due dates.
Finding: Item 2020-006 ? Reporting: Delinquent Reports Management?s View ? We concur with the finding with Exception: Corrective Action Plan (CAP) ? All SF-425 reports are being filed in a timely manner and data used to file the reports are queried directly from our accounting system (support is filed with the report in the Controller?s Office). Grant requirements for Indian Health Services state that a quarterly SF-425 be filed no later than the last day of the month following the end of any given quarter. That requirement is being met. WIOA requirements for SF-425 (referenced as their Federal Financial Report) be filed no later than 45 days after the end of any given quarter. That requirement is being met. The annual Inventory report for the current audit period that is to be filed with the Property Agent in Oklahoma City was filed on October 29, 2019 prior to the required filing requirement of December 31, 2019. Our Annual Inventory report for the following audit period was filed with The Property Agent in Oklahoma City on December 29, 2020 prior to the required filing date of December 31, 2020. We are now in complete compliance with reporting requirements and no further corrective action plan is required.
2019-006
Criteria: In accordance with 2 CFR 200.512, the single audit reporting package must be submitted to the federal audit clearinghouse within nine months after the end of the audit period. Condition/context: The Center's single audit for the year ended June 30, 2019, which was required to be submitted by March 31, 2020, was submitted on September 23, 2020. Cause: The June 30, 2019, audit was delayed due to the Center requiring additional time to close the general ledger. Effect: This noncompliance causes the Center to automatically be considered a high- risk entity as defined by the Uniform Guidance. Questioned cost: N/a Repeat finding: Finding is a repeat of finding 2019-007 in the immediately prior audit. Recommendation: Complete the audit and federal audit clearinghouse filing within the nine-month window.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 2 CFR 200.512, the single audit reporting package must be submitted to the federal audit clearinghouse within nine months after the end of the audit period. Condition/context: The Center's single audit for the year ended June 30, 2019, which was required to be submitted by March 31, 2020, was submitted on September 23, 2020. Cause: The June 30, 2019, audit was delayed due to the Center requiring additional time to close the general ledger. Effect: This noncompliance causes the Center to automatically be considered a high- risk entity as defined by the Uniform Guidance. Questioned cost: N/a Repeat finding: Finding is a repeat of finding 2019-007 in the immediately prior audit. Recommendation: Complete the audit and federal audit clearinghouse filing within the nine-month window.
Finding: Item 2020-007 ? Reporting: Data Collection Form Management?s View ? We concur with the finding. Annual audits should take place and be complete no later than October 31st of any given year. Delay in completion of the annual audit has a detrimental effect on the entire organization as key reports cannot be completed in a timely manner. The inability to complete these reports creates several issues especially related to the proper Indirect Cost Rate used for Administrative purposes and the collection of Medicare/Medicaid payments due to the late filing of our Annual Medicare Cost Report. Corrective Action Plan (CAP) ? Completion of our 2020 Single Audit with assurance going forward that our annual Single Audit will be completed no later than September 30th of any given year will allow us to meet all internal and external reporting requirements in a timely manner. That is the goal of the organization and one that will be fulfilled going forward. The Controller for the organization is responsible for this CAP timeline.
2019-007
Criteria: On June 20, 2018, the Office of Management and Budget (OMB) issued a memorandum Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance. The memorandum increased certain thresholds for procurement and clarified the effective date of the Uniform Guidance procurement rules, which were effective for the Center on July 1, 2018. Condition/context: The Center's procurement policy in use during fiscal year 2020 was from July 2011, and did not contain all the necessary elements required by UGG. Cause: The Center had not completed an update of its procurement policy to implement the requirements under Uniform Guidance. Effect: Potential for the Center to not follow federally mandated procurement procedures. Questioned cost: n/a Repeat finding: Finding is a repeat of finding 2019-008 in the immediately prior audit. Recommendation: Management should complete the update of its procurement policy to be in compliance with the procurement requirements of the Uniform Guidance and perform an assessment of expenditures beginning July 1, 2018, for potential noncompliance with UGG. We also recommend that the responsibility for the procurement policy be clearly defined and documented.
Show full finding ▾Hide full finding ▴Criteria: On June 20, 2018, the Office of Management and Budget (OMB) issued a memorandum Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance. The memorandum increased certain thresholds for procurement and clarified the effective date of the Uniform Guidance procurement rules, which were effective for the Center on July 1, 2018. Condition/context: The Center's procurement policy in use during fiscal year 2020 was from July 2011, and did not contain all the necessary elements required by UGG. Cause: The Center had not completed an update of its procurement policy to implement the requirements under Uniform Guidance. Effect: Potential for the Center to not follow federally mandated procurement procedures. Questioned cost: n/a Repeat finding: Finding is a repeat of finding 2019-008 in the immediately prior audit. Recommendation: Management should complete the update of its procurement policy to be in compliance with the procurement requirements of the Uniform Guidance and perform an assessment of expenditures beginning July 1, 2018, for potential noncompliance with UGG. We also recommend that the responsibility for the procurement policy be clearly defined and documented.
Finding: Item 2020-008 ? Procurement: Procurement Policy Management?s View ? We concur with the finding. The organization has worked to complete its procurement policy ensuring compliance with Uniform Guidance through a complete revision of its Fiscal Policies and Procedures. Corrective Action Plan (CAP) ? The Controller for the Organization has completely re-written new Fiscal Policies and Procedures which include the Procurement process for the organization that encompass the requirement within Uniform Guidance. Said Policies and Procedures were provided to the Board of Directors in February 2020. The Board Treasurer has prepared a Board Resolution for adoption of the new Policies and Procedures to present at our Board Meeting in December 2020. The new Fiscal Policy and Procedure for Uniform Guidance was formally adopted by Corporate Resolution at said meeting in December 2020 and is currently being implemented. No further corrective action plan is required for this finding.
2019-008
FAC accepted this audit on September 22, 2020 — management decision was due March 22, 2021.
Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition/context: Dollar amounts in the grant reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: As reported in finding 2019-001, certain general ledger accounts were reconciled after year-end, causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports.
Show full finding ▾Hide full finding ▴Criteria: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards section 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition/context: Dollar amounts in the grant reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: As reported in finding 2019-001, certain general ledger accounts were reconciled after year-end, causing the general ledger to no longer agree to the amounts originally reported in the financial reports. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-005 in the immediately prior audit. Recommendation: General ledger accounts should be timely reconciled. Printouts or exports of the general ledger should be maintained to support the amounts in financial reports.
Finding: Item 2019-005 ? Internal Controls over Federal Programs Management?s View ? We concur with the finding. General Ledger accounts must be reconciled to Federal Awards and subsequently to reporting that is submitted to the Federal Agency. Corrective Action Plan (CAP) ? The organization has defined policy and procedures that directs the closure of the ledgers on a monthly basis. This process includes verification that all Federal PMS Drawn Downs have been recorded in the Ledgers, that all funds transferred between accounts are reconciled and that accruals are recorded in a timely manner. Assurance that all bank accounts are completely reconciled is a key component in the process. The Controller for the organization has begun training the Senior Accountant on the process and will work directly with him to ensure that UITCT accounting staff performs a full reconciliation of all accounts with assurance that said reconciliation will be maintained on a consistent basis. We have accomplished much of this task and will work diligently to ensure its continued integrity. This is an ongoing process but will be completed no later than October 31, 2020 by the Controller and the Senior Accountant.
2018-005
Criteria: The grant agreements for Urban Indian Health Services requires certain reports to be filed within 45 days of quarter-end, and an annual inventory to be submitted by December 31 to the IHS Property Administrator. Condition/context: There were several occurrences of reports not being timely filed or not being filed. The annual inventory was not submitted by December 31 to the IHS Property Administrator. Form SF-425 for the Urban Indian Health Services grant were not submitted quarterly. Additionally, dollar amounts in the reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: The Center does not have internal controls in place to monitor report due dates. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-006 in the immediately prior audit. Recommendation: Management should maintain a master summary schedule that identifies the responsible parties and details all report due dates.
Show full finding ▾Hide full finding ▴Criteria: The grant agreements for Urban Indian Health Services requires certain reports to be filed within 45 days of quarter-end, and an annual inventory to be submitted by December 31 to the IHS Property Administrator. Condition/context: There were several occurrences of reports not being timely filed or not being filed. The annual inventory was not submitted by December 31 to the IHS Property Administrator. Form SF-425 for the Urban Indian Health Services grant were not submitted quarterly. Additionally, dollar amounts in the reports were difficult to reconcile back to the general ledger, and documentation was not maintained to substantiate how the reported amounts were compiled. Cause: The Center does not have internal controls in place to monitor report due dates. Effect: Continual noncompliance with grants could result in the loss of grant funds or additional federal oversight. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-006 in the immediately prior audit. Recommendation: Management should maintain a master summary schedule that identifies the responsible parties and details all report due dates.
Finding: Item 2019-006 ? Reporting: Delinquent Reports Management?s View ? We concur with the finding. Due to the turn- over in staff, monthly, quarterly and annual reports to Federal agencies were in some instances filed on a late basis. All reports where we have ability to file, have been filed with exception of our Annual Indirect Cost Report and our 2019 Annual Medicare Cost Report. Corrective Action Plan (CAP) ? Carlton Roach, Controller, has purchased a subscription to Fluxx Grant Management Software. The system was purchased on May 31, 2020 but due to the Covid-19 issue in Dallas has been delayed in its deployment. Our staff will be returning to the office on October 01, 2020 and we will begin input of all Contracts, Grants and Foundation Awards so we may track all reporting requirements as defined in the documents obtained from the funding agency. The CAP timeline for this system will be November 30, 2020 and it is the responsibility of the Controller to ensure all staff who manage a contract and/or grant are fully trained and are managing their workflow within the system. Fluxx is a very robust system and more information regarding the system may be viewed at the following URL: www.flux.io
2018-006
Criteria: In accordance with 2 CFR 200.512, the single audit reporting package must be submitted to the federal audit clearinghouse within nine months after the end of the audit period. Condition/context: The Center's single audit for the year ended June 30, 2018, which was required to be submitted by March 31, 2019, was submitted on December 19, 2019. Cause: The June 30, 2018, audit was delayed due to the Center requiring additional time to close the general ledger. Effect: This noncompliance causes the Center to automatically be considered a high- risk entity as defined by the Uniform Guidance. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-007 in the immediately prior audit. Recommendation: Complete the audit and federal audit clearinghouse filing within the nine-month window.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 2 CFR 200.512, the single audit reporting package must be submitted to the federal audit clearinghouse within nine months after the end of the audit period. Condition/context: The Center's single audit for the year ended June 30, 2018, which was required to be submitted by March 31, 2019, was submitted on December 19, 2019. Cause: The June 30, 2018, audit was delayed due to the Center requiring additional time to close the general ledger. Effect: This noncompliance causes the Center to automatically be considered a high- risk entity as defined by the Uniform Guidance. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-007 in the immediately prior audit. Recommendation: Complete the audit and federal audit clearinghouse filing within the nine-month window.
Finding: Item 2019-007 ? Reporting: Data Collection Form Management?s View ? We concur with the finding. Annual audits should take place and be complete no later than October 31st of any given year. Delay in completion of the annual audit has a detrimental effect on the entire organization as key reports cannot be completed in a timely manner. The inability to complete these reports creates several issues especially related to the proper Indirect Cost Rate used for Administrative purposes and the collection of Medicare/Medicaid payments due to the late filing of our Annual Medicare Cost Report. Corrective Action Plan (CAP) ? We are completing the 2019 audit and will within 4 to 6 weeks begin the 2020 audit. Our goal will be 2020 audit completion no later than the last day of October 2020. After completion of the 2020 audit, we will work diligently to ensure the annual Single Audit is completed no later than October 31st of any given year. The Controller for the organization is responsible for this CAP timeline.
2018-007
Criteria: The Center is required to follow 2 CFR ?200.318 General procurement standards through ?200.326 Contract provisions. On June 20, 2018, the Office of Management and Budget (OMB) issued a memorandum Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance. The memorandum increased certain thresholds for procurement and clarified the effective date of the Uniform Guidance procurement rules, which were effective for the Center on July 1, 2018. Condition/context: The Center's procurement policy in use during fiscal year 2019 was from July 2011, and did not contain all the necessary elements required by UGG. Cause: The Center had not completed an update of its procurement policy to implement the requirements under UGG. Effect: Potential for the Center to not follow federally-mandated procurement procedures. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-008 in the immediately prior audit. Recommendation: Management should complete the update of its procurement policy to be in compliance with the procurement requirements of the Uniform Guidance and perform an assessment of expenditures beginning July 1, 2018, for potential noncompliance with UGG. We also recommend that the responsibility for the procurement policy be clearly defined and documented.
Show full finding ▾Hide full finding ▴Criteria: The Center is required to follow 2 CFR ?200.318 General procurement standards through ?200.326 Contract provisions. On June 20, 2018, the Office of Management and Budget (OMB) issued a memorandum Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance. The memorandum increased certain thresholds for procurement and clarified the effective date of the Uniform Guidance procurement rules, which were effective for the Center on July 1, 2018. Condition/context: The Center's procurement policy in use during fiscal year 2019 was from July 2011, and did not contain all the necessary elements required by UGG. Cause: The Center had not completed an update of its procurement policy to implement the requirements under UGG. Effect: Potential for the Center to not follow federally-mandated procurement procedures. Questioned cost: Not applicable. Repeat finding: Finding is a repeat of finding 2018-008 in the immediately prior audit. Recommendation: Management should complete the update of its procurement policy to be in compliance with the procurement requirements of the Uniform Guidance and perform an assessment of expenditures beginning July 1, 2018, for potential noncompliance with UGG. We also recommend that the responsibility for the procurement policy be clearly defined and documented.
Finding: Item 2019-008 ? Procurement: Procurement Policy Management?s View ? We concur with the finding. The organization has worked to complete its procurement policy ensuring compliance with Uniform Guidance through a complete revision of its Fiscal Policies and Procedures. Corrective Action Plan (CAP) ? The Controller for the Organization has completely re-written new Fiscal Policies and Procedures which include the Procurement process for the organization that encompass the requirement within Uniform Guidance. Said Policies and Procedures were provided to the Board of Directors in February 2020. The Board Treasurer is preparing a Board Resolution for adoption of the new Policies and Procedures to present at our Board Meeting in October 2020. A copy of these policies and procedures were provided to the Audit firm during the 2019 audit as assurance that this issue was being addressed. Upon acceptance by our Board of Directors, we consider this finding CAP closed and no further action will be required until such time as revision is required based on changing accounting standards.
2018-008
FAC accepted this audit on November 4, 2019 — management decision was due May 4, 2020.
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Show full finding ▾Hide full finding ▴FAC accepted this audit on March 27, 2017 — management decision was due September 27, 2017.
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