BENEFIS HEALTH SYSTEM, INC., AND AFFILIATESNon-Profit

Criteria – In accordance with the Uniform Guidance (2 CFR Part 200), Subpart E – Cost Principles, and the program’s grant agreement, costs charged to federal awards must be necessary, reasonable, and applicable to the federal program. Condition/Context – The Organization did not have an effective review process for ensuring that federal expenditures were properly allocated and not claimed under multiple federal grants. The initial sample identified expenditures that had already been reimbursed by a different federal grant program. The Organization reported the issue and received approval from the agency to re-establish the population to exclude the costs that were already allocated to another federal grant in a previous period. Effect – While the Organization consulted with the funding agency and received approval to provide an updated population, the original population included expenditures that were already reimbursed by another federal grant program. That process required more time, and the Organization missed the single audit submission deadline. Cause – The primary cause of this finding is insufficient coordination between the Organization and the consultant that assisted with the grant application, coupled with the Organization’s lack of familiarity with the funding agency’s process. The resulting review process did not detect the inclusion of expenditures reimbursed by a different federal grant program. Repeat Finding – This is not a repeat finding. Recommendation – To help prevent the same costs being reported and reimbursed by more than one grant program, we recommend the Organization establish and implement a comprehensive review of program expenditures that could be allowable under multiple programs. Views of Responsible Officials – The responsible officials acknowledge the finding, concur with the recommendation and noted that corrective action has been taken.