The Josselyn CenterNon-Profit

Department of Health and Human Services and Department of Treasury 2025-001 Coronavirus State and Local Fiscal Recovery Funds (Allowable Costs, Period of Performance, and Procurement) and Congressional Directives (Procurement) Criteria: Under 2 CFR 200.302 and 200.403, non-federal entities must maintain records sufficient to demonstrate that costs charged to Federal Awards are allowable, properly allocated and adequately supported. Under 2 CFR 200.309 costs must provide documentation that costs were incurred within the approved period of performance. Additional 2 CFR 200.317-200.327 requires entities to maintain documentation sufficient to support the procurement process for the use of Federal Awards. Condition: The Center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Allowable Costs – The Center provided grant allocation worksheets that show individual employees hours charged to the federal awards; however, the grant allocation worksheets did not include any employee or supervisor signatures to attest the hour allocations were accurate. Additionally, certain invoices had a portion of the total costs allocated to the federal award, but the Center could not substantiate the basis for the allocation. Period of Performance – The Center had charged costs to the federal award for costs incurred outside the period of performance as defined by the grant agreement but could not provide documentation that supported the grantor allowed charges to be made for costs incurred outside that period. Procurement – The Center entered a contract with a Company under the Simple Acquisition threshold for procurement but was unable to provide documentation that quotes were obtained from multiple qualified vendors. Cause: The Center did not have effective controls in place to ensure proper documentation was obtained and retained to support compliance with the federal award. Effect: Without adequate supporting documentation the Organization is unable to demonstrate its compliance with all requirements of the federal award. Questioned Costs: $175,389 out of $2,453,443 of total expenditures tested. Auditor’s Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management Response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR $$ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Department of Health and Human Services 2024-002 (Repeat finding 2023-003) Block Grants for Community Mental Health Services Criteria: Under 2 CFR 200.430(i)(1)(i) charges to Federal Awards for salaries and wages must be based on records that accurately reflect work performed and be supported with documentation that reasonable assure that the charges are accurate, allowable, and properly allocation and reasonably reflect the total activity for which the employee is compensated. Condition: The documentation to support reasonable assurance for salaries and wages consisted of documentation of when employees completed a therapy session but no clear documentation of how much time when employees were on-call or completed case notes for this grant. Cause: The documentation to support time and effort of employee’s salaries did not include all of the hour’s employees spent on the grant. The Center employees spend hours working outside the therapy session that relate to providing the best help for their clients’ needs. Effect: There is not proper documentation to support the allocation of time and effort that was charged to the grant. Auditor’s Recommendation: We recommend The Center remind its employees complete a personnel activity report that show all of the hours employees spend on the grant not rely just hours documented in the Center system used to track therapy sessions. Management response: Management agrees with the finding and already has a process in place for documenting time spent on grant funded activities. Management is working with our Chief Compliance Officer to ensure that the process encompasses all necessary steps to ensure complete and accurate records of the grant related activities by those who have the time covered by the grant funds.

Department of Health and Human Services 2023-003 Block Grants for Community Mental Health Services Criteria: Under 2 CFR 200.430(i)(1)(i) charges to Federal Awards for salaries and wages must be based on records that accurately reflect work performed and be supported with documentation that reasonable assure that the charges are accurate, allowable, and properly allocation and reasonably reflect the total activity for which the employee is compensated. Condition: The documentation to support reasonable assurance for salaries and wages consisted of documentation of when employees completed a therapy session but no clear documentation of how much time when employees were on-call or completed case notes for this grant. Cause: The documentation to support time and effort of employee’s salaries did not include all of the hour’s employees spent on the grant. The Center employees spend hours working outside the therapy session that relate to providing the best help for their clients’ needs. Effect: There is not proper documentation to support the allocation of time and effort that was charged to the grant. Auditor’s Recommendation: We recommend The Center remind its employees complete a personnel activity report that show all of the hours employees spend on the grant not rely just hours documented in the Center system used to track therapy sessions. Management response: While each grant budget and requirement is different, Management agrees with the recommendation as a more complete process for documenting the time and will work towards implementing the additional time coverage to our procedures.