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Okanogan Behavorial HealthcareNon-Profit

EIN: 412040765

UEI: VN3NUK5M7HJ9

Audited by: CLIFTONLARSONALLEN LLP

Oversight agency: 93 [Department of Health and Human Services]

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Data as of September 2, 2026

Okanogan Behavorial Healthcare4 audit years12 findings1 repeat
4
Audit Years
12
Total Findings
1
Repeat Findings
$2.3M
Federal Awards Expended (FY 2023)

FY 2023-06-30

$2,253,422 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 12, 2024. 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 April 12, 2025 (512 days ago).

What is a management decision? →
2023-001
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2022-002OTHER MATTERS

During audit procedures performed, we noted two payroll transactions tested included a pay date prior to the beginning period of performance, and the payroll costs were charged to the grant. Questioned costs: None. Context: During audit procedures performed, we tested five payroll transactions for beginning period of performance testing related to ALN 93.959 and noted one of the transactions had a pay period that began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. During payroll testing performed related to allowable costs and activities, of the 10 payroll transactions selected for testing, one was noted in which the pay period was prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Cause: OBHC’s internal controls lacked proper procedures to ensure expenditures were not being charged to the grant if it was not incurred within the period of performance. Effect: OBHC charged expenditures to the grants and was reimbursed for these costs that included payroll costs incurred outside of the contract period of performance. Repeat finding: The finding is a repeat of a finding in the immediate prior year. Prior year finding number was 2022-002. Recommendation: We recommend that OBHC develop a procedure to ensure that payroll transactions are properly allocated to grants and charged to grant awards based on the dates incurred to ensure the costs are within the period of performance. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG) Assistance Listing Number: 93.959 Federal Award Identification Number and Year: K6103.01 – 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K6103.01 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance – Period of Performance; Other Matters Criteria or specific requirement: Under §200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance applicable to the grant. Condition: During audit procedures performed, we noted two payroll transactions tested included a pay date prior to the beginning period of performance, and the payroll costs were charged to the grant. Questioned costs: None. Context: During audit procedures performed, we tested five payroll transactions for beginning period of performance testing related to ALN 93.959 and noted one of the transactions had a pay period that began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. During payroll testing performed related to allowable costs and activities, of the 10 payroll transactions selected for testing, one was noted in which the pay period was prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Cause: OBHC’s internal controls lacked proper procedures to ensure expenditures were not being charged to the grant if it was not incurred within the period of performance. Effect: OBHC charged expenditures to the grants and was reimbursed for these costs that included payroll costs incurred outside of the contract period of performance. Repeat finding: The finding is a repeat of a finding in the immediate prior year. Prior year finding number was 2022-002. Recommendation: We recommend that OBHC develop a procedure to ensure that payroll transactions are properly allocated to grants and charged to grant awards based on the dates incurred to ensure the costs are within the period of performance. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The Finance team corrected their processes to ensure proper recording of payroll costs during the time of the FY22 Audit procedures; however, the changes were made to subsequent months and previously submitted months were not retroactively corrected. Additionally, the OBHC team is currently working with the HCA in restructuring the rate schedule to incorporate the payroll costs into the direct service rates for the SOR/SABG grants. This effectively removes this issue going forward in FY25 once approved by the HCA. Name(s) of the contact person(s) responsible for corrective action: Carrie Anthony Planned completion date for corrective action plan: Sep 2023 & New rates: Sep 30, 2024

Prior Finding References

2022-002

About Period of Performance →
2023-002
Activities Allowed or Unallowed / Cost Allowability / Cash Management
SIGNIFICANT DEFICIENCY

Grant billings are to be reviewed and approved by the CFO or CEO prior to submitting to the granting agency. There was no documentation of review and approval by the CFO or CEO. Questioned costs: None. Context: There was no prior review and approval indicated on any of the cash management drawdowns reviewed as part of audit testing. Cause: Inadequate implementation of internal controls over compliance related to cash management and indirect costs. There was also turnover in the CFO position during the fiscal year. Effect: Lack of an independent review and approval of grant billings resulted in incorrect items being included on the billings and errors going undetected. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all grant draw requests are reviewed in detail with support for the expenditures and approved by an individual separate from the one preparing the draw request prior to submission to the granting agency. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG); SOR Recovery Support Services Assistance Listing Number: 93.959 and 93.788 Federal Award Identification Number and Year: K6103.01 – 2023, 1009592.16 – 2023, K4849-02 – 2022, K6479 - 2023 Pass-Through Agency: Washington State Health Care Authority; Beacon Health Options, Inc. Pass-Through Number(s): K6103.01, 1009592.16, K4849-02, K6479 Award Period: July 1, 2022 – June 30, 2023; September 30, 2020 – September 29, 2022; September 29, 2022 – September 28, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Proper internal controls over cash management and indirect costs include the review and approval of grant draws prior to submission to the granting agency, to ensure accuracy of expenditures. Condition: Grant billings are to be reviewed and approved by the CFO or CEO prior to submitting to the granting agency. There was no documentation of review and approval by the CFO or CEO. Questioned costs: None. Context: There was no prior review and approval indicated on any of the cash management drawdowns reviewed as part of audit testing. Cause: Inadequate implementation of internal controls over compliance related to cash management and indirect costs. There was also turnover in the CFO position during the fiscal year. Effect: Lack of an independent review and approval of grant billings resulted in incorrect items being included on the billings and errors going undetected. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all grant draw requests are reviewed in detail with support for the expenditures and approved by an individual separate from the one preparing the draw request prior to submission to the granting agency. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The new CFO reviews and approves federal grant draw requests prior to the submission to the granting agency. Name(s) of the contact person(s) responsible for corrective action: Carrie Anthony Planned completion date for corrective action plan: August 31, 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management →
2023-003
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

For one transaction selected for testing, support for the disbursement included a vendor invoice for $252.25, however, the amount paid to the vendor on behalf of the client was $302.25 and there was no support for the $50 additional. The grant is a reimbursement-based grant. As such, there was insufficient support for $50 of federal expenditures. Questioned costs: None. Context: Of the nine general disbursements tested for period of performance, one was noted in which the total amount expended was $302.25, however, the supporting invoice was for $252.25, resulting in $50 that was unsupported. Cause: After paying the supported invoice, the client would have had $50 left of eligible grant funds after the bill payment. Program management added the remaining $50 to the expenditure amount to be put towards the client's future power bill. Effect: Support was not available for $50 of program expenditures charged to the grant. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all expenditures charged to the grant have been incurred and are supported by invoice or other documentation and retained by OBHC. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG) Assistance Listing Number: 93.959 Federal Award Identification Number and Year: K6103.01 – 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K6103.01 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance – Allowable Costs and Activities; Other Matters Criteria or specific requirement: Under §200.403, costs must meet specific criteria to be allowable under Federal awards and be adequately documented. Condition: For one transaction selected for testing, support for the disbursement included a vendor invoice for $252.25, however, the amount paid to the vendor on behalf of the client was $302.25 and there was no support for the $50 additional. The grant is a reimbursement-based grant. As such, there was insufficient support for $50 of federal expenditures. Questioned costs: None. Context: Of the nine general disbursements tested for period of performance, one was noted in which the total amount expended was $302.25, however, the supporting invoice was for $252.25, resulting in $50 that was unsupported. Cause: After paying the supported invoice, the client would have had $50 left of eligible grant funds after the bill payment. Program management added the remaining $50 to the expenditure amount to be put towards the client's future power bill. Effect: Support was not available for $50 of program expenditures charged to the grant. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all expenditures charged to the grant have been incurred and are supported by invoice or other documentation and retained by OBHC. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The program experienced transition in management and staff during FY23. The new Recovery Support Services staff are now fully trained and ensures expenditures are incurred, charged appropriately and supporting documentation is maintained on file. Additionally, AP and Finance team review supporting documentation and ensure completeness. Name(s) of the contact person(s) responsible for corrective action: Floral Reed Planned completion date for corrective action plan: June 30, 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-004
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

There were two general disbursements identified during allowable costs and activities testing that did not have documentation of proper expense approval by the program supervisor. Questioned costs: None. Context: Internal Controls tested during allowable costs and activities testing included the proper documentation of supervisor approval for expenses. Of the 30 general disbursements tested for allowable costs and activities, two did not have support for supervisory approval. Cause: Lack of review and approval of specific expenditures appears to be an internal control oversight. Effect: Lack of supervisory approval of expenditures could result in costs allocated to the grant that are not allowable. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all invoices are approved by a supervisor knowledgeable of the grant requirements prior to payment by the accounting department, and that documentation of this review is retained. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG) Assistance Listing Number: 93.959 Federal Award Identification Number and Year: K6103.01 – 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K6103.01 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Proper internal controls over general disbursements include the review and approval of expenditures by a supervisor prior to payment. Condition: There were two general disbursements identified during allowable costs and activities testing that did not have documentation of proper expense approval by the program supervisor. Questioned costs: None. Context: Internal Controls tested during allowable costs and activities testing included the proper documentation of supervisor approval for expenses. Of the 30 general disbursements tested for allowable costs and activities, two did not have support for supervisory approval. Cause: Lack of review and approval of specific expenditures appears to be an internal control oversight. Effect: Lack of supervisory approval of expenditures could result in costs allocated to the grant that are not allowable. Repeat finding: Not a repeat finding. Recommendation: CLA recommends that all invoices are approved by a supervisor knowledgeable of the grant requirements prior to payment by the accounting department, and that documentation of this review is retained. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: The program experienced transition in management and staff during FY23. The new Recovery Support Services staff are now fully trained and ensures expenditures are charged appropriately, approved by a knowledgeable supervisor, and supporting documentation is maintained on file. Additionally, AP and Finance team review supporting documentation and ensure completeness. Name(s) of the contact person(s) responsible for corrective action: Floral Reed Planned completion date for corrective action plan: June 30, 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-005
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

The payroll expenditures included on the February 2023 reimbursement request were determined based on February 2022 payroll activity, rather than the February 2023 payroll activity. Questioned costs: None. Context: Of the six reimbursement requests tested for SABG and five for SOR, noted one for each grant (same time period) in which incorrect pay periods were used to determine the amount of reimbursement to claim. For the payroll transactions selected for testing, two out of 10 for SABG and two out of eight for SOR were for payroll costs incurred in February 2022 and were not within the grant period. Cause: Payroll activity for the wrong year was used to determine the amount to claim for expense reimbursement. Effect: Payroll expenditures were overcharged to the grant. Repeat finding: Not a repeat finding. Recommendation: We recommend all grant billings are reviewed and approved by an individual independent of the preparation process and that this review includes reviewing supporting documentation for the expenditures being claimed to ensure the amount charged to the grant is accurate. Views of responsible officials: There is no disagreement with the audit finding

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG); SOR Recovery Support Services Assistance Listing Number: 93.959 and 93.788 Federal Award Identification Number and Year: K6103.01 – 2023, K6479 - 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K6103.01, K6479 Award Period: July 1, 2022 – June 30, 2023; September 29, 2022 – September 28, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance – Allowable Costs and Activities,Cash Management, and Period of Performance; Other Matters Criteria or specific requirement: Proper internal controls over cash management and indirect costs include the review and approval of grant draws prior to submission to the granting agency, to ensure accuracy of expenditures. Condition: The payroll expenditures included on the February 2023 reimbursement request were determined based on February 2022 payroll activity, rather than the February 2023 payroll activity. Questioned costs: None. Context: Of the six reimbursement requests tested for SABG and five for SOR, noted one for each grant (same time period) in which incorrect pay periods were used to determine the amount of reimbursement to claim. For the payroll transactions selected for testing, two out of 10 for SABG and two out of eight for SOR were for payroll costs incurred in February 2022 and were not within the grant period. Cause: Payroll activity for the wrong year was used to determine the amount to claim for expense reimbursement. Effect: Payroll expenditures were overcharged to the grant. Repeat finding: Not a repeat finding. Recommendation: We recommend all grant billings are reviewed and approved by an individual independent of the preparation process and that this review includes reviewing supporting documentation for the expenditures being claimed to ensure the amount charged to the grant is accurate. Views of responsible officials: There is no disagreement with the audit finding

Corrective Action Plan

Action taken in response to finding: The new CFO reviews and approves federal grant draw requests prior to the submission to the granting agency. Name(s) of the contact person(s) responsible for corrective action: Carrie Anthony Planned completion date for corrective action plan: August 31, 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management, Period of Performance →
2023-006
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSOTHER MATTERS

Time sheets did not indicate the project/grant the employee worked on for the pay period to support allocation to the grant. For July 2022 through January 2023 payroll costs were charged 100% to either ALN 93.959 or ALN 93.788 and were not allocated based on the employee's time spent working in the programs. For February 2023 through June 2023 payroll costs were allocated to the grants based on the amount of expenses paid on behalf of program participants during the month for items such as rent, groceries, utilities, etc. Questioned costs: None. Context: For the payroll transactions selected for testing, all eight of the SABG payroll transactions were not supported by time and effort records. Time and effort was not properly tracked during the audit period between the SABG and SOR program, however, based on the effort expended providing services to program participants, costs meet the allowable costs and activities requirements. Cause: Time and effort between the SOR and SABG programs was not tracked during the audit period to accurately allocate time between the programs. Effect: Payroll costs were not charged to the program based on time and effort. Repeat finding: Not a repeat finding. Recommendation: We recommend time spent on the SABG program be coded to a unique project code in order to ensure time and effort is properly identified and tracked for the program. Views of responsible officials: There is no disagreement with the audit finding

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG) Assistance Listing Number: 93.959 Federal Award Identification Number and Year: K6103.01 – 2023, 1009592.16 - 2023 Pass-Through Agency: Washington State Health Care Authority; Beacon Health Options, Inc. Pass-Through Number(s): K6103.01 and 1009592.16 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance – Allowable Costs and Activities; Other Matters Criteria or specific requirement: Proper internal controls over time and effort are to be in place in order to enusre payroll costs are properly charged to grants. Condition: Time sheets did not indicate the project/grant the employee worked on for the pay period to support allocation to the grant. For July 2022 through January 2023 payroll costs were charged 100% to either ALN 93.959 or ALN 93.788 and were not allocated based on the employee's time spent working in the programs. For February 2023 through June 2023 payroll costs were allocated to the grants based on the amount of expenses paid on behalf of program participants during the month for items such as rent, groceries, utilities, etc. Questioned costs: None. Context: For the payroll transactions selected for testing, all eight of the SABG payroll transactions were not supported by time and effort records. Time and effort was not properly tracked during the audit period between the SABG and SOR program, however, based on the effort expended providing services to program participants, costs meet the allowable costs and activities requirements. Cause: Time and effort between the SOR and SABG programs was not tracked during the audit period to accurately allocate time between the programs. Effect: Payroll costs were not charged to the program based on time and effort. Repeat finding: Not a repeat finding. Recommendation: We recommend time spent on the SABG program be coded to a unique project code in order to ensure time and effort is properly identified and tracked for the program. Views of responsible officials: There is no disagreement with the audit finding

Corrective Action Plan

Action taken in response to finding: OBHC implemented new payroll software in March 2023. During FY24, staff were trained to directly allocate their time to programs in their electronic timecard. Effective Feb 2024, time and effort reporting was used to allocate salaries to the SABG program. Additionally, the OBHC team is currently working with the HCA in restructuring the rate schedule to incorporate the payroll costs into the direct service rates for the SOR/SABG grants. This effectively removes this issue going forward in FY25 once approved by the HCA. Name(s) of the contact person(s) responsible for corrective action: Patty Brandt Planned completion date for corrective action plan: Feb 2024 & Sep 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-007
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Of the six client service reimbursements tested for SABG, three were incorrectly charged to the grant. Of these three, two of the errors were identified by the client in during February 2024 and steps taken with the granting agency to correct these. Of the five client service reimbursements tested for SOR, five were incorrectly charged to the grant. Of these five, three of the errors were identified by the client in September 2023 and steps taken with the granting agency to correct these. Client service reimbursements were calculated using incorrect program service information (i.e., SABG client services were used to determine SOR client service reimbursement amounts),and hours were not supported by the client service data. Questioned costs: None. Context: Three of the six monthly billings for the SABG program had incorrectly calculated client service reimbursement amounts for the Client Service reimbursement, which resulted in an incorrect amount being charged to the grant. Five of the five monthly billings for the SOR program had incorrectly calculated client service reimbursement amounts for the Client Service reimbursement, which resulted in an incorrect amount being charged to the grant. Cause: The service hour support calculations were incorrectly determined, and these incorrect calculations were used to complete the monthly grant billing. Effect: Client service hours were incorrectly charged to the grant. Repeat finding: Not a repeat finding. Recommendation: We recommend grant billers ensure service reports for the proper program and time period are used to calculate the client service billing amount. We also recommend the data used to determine this amount be reviewed and approved during the grant billing review process Views of responsible officials: There is no disagreement with the audit finding

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse Prevention and Treatment Block Grant (SABG); SOR Recovery Support Services Assistance Listing Number: 93.959 and 93.788 Federal Award Identification Number and Year: K6103.01 – 2023, K4849-02 – 2022; K6479 - 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K6103.01 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance – Allowable Costs and Activities; Other Matters Criteria or specific requirement: Proper internal controls over cash management include the review and approval of grant draws prior to submission to the granting agency, to ensure accuracy of expenditures and client services claimed on the invoices. Condition: Of the six client service reimbursements tested for SABG, three were incorrectly charged to the grant. Of these three, two of the errors were identified by the client in during February 2024 and steps taken with the granting agency to correct these. Of the five client service reimbursements tested for SOR, five were incorrectly charged to the grant. Of these five, three of the errors were identified by the client in September 2023 and steps taken with the granting agency to correct these. Client service reimbursements were calculated using incorrect program service information (i.e., SABG client services were used to determine SOR client service reimbursement amounts),and hours were not supported by the client service data. Questioned costs: None. Context: Three of the six monthly billings for the SABG program had incorrectly calculated client service reimbursement amounts for the Client Service reimbursement, which resulted in an incorrect amount being charged to the grant. Five of the five monthly billings for the SOR program had incorrectly calculated client service reimbursement amounts for the Client Service reimbursement, which resulted in an incorrect amount being charged to the grant. Cause: The service hour support calculations were incorrectly determined, and these incorrect calculations were used to complete the monthly grant billing. Effect: Client service hours were incorrectly charged to the grant. Repeat finding: Not a repeat finding. Recommendation: We recommend grant billers ensure service reports for the proper program and time period are used to calculate the client service billing amount. We also recommend the data used to determine this amount be reviewed and approved during the grant billing review process Views of responsible officials: There is no disagreement with the audit finding

Corrective Action Plan

Action taken in response to finding: The grant biller performs additional review of grant billings for accuracy. In addition, the new CFO reviews and approves at a detailed level the grant billing. Name(s) of the contact person(s) responsible for corrective action: Patty Brandt Planned completion date for corrective action plan: August 31, 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-008
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

Time sheets did not indicate the project/grant the employee worked on for the pay period to support allocation to the grant. For July 2022 through January 2023 payroll costs were charged 100% to either ALN 93.959 or ALN 93.788 and were not allocated based on the employee's time spent working in the programs. For February 2023 through June 2023 payroll costs were allocated to the grants based on the amount of expenses paid on behalf of program participants during the month for items such as rent, groceries, utilities, etc. Questioned costs: Unknown due to inadequate tracking of time. Context: Of the 10 payroll transactions tested for the SOR program, one was properly charged to the grant and supported by time and effort documentation. Time and effort was not properly tracked during the audit period between the SOR and SABG program. Eligibility requirements for the SOR program are more restrictive, thus not all time spent providing services to SABG and SOR participants would meet the allowable costs and activities requirements of the program. Cause: Time and effort between the SOR and SABG programs was not tracked during the audit period to accurately allocate time between the programs. Effect: Payroll costs were not charged to the program based on time and effort. Repeat finding: Not a repeat finding. Recommendation: We recommend time spent on the SOR program be coded to a unique project code in order to ensure time and effort is properly identified and tracked for the program. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: SOR Recovery Support Services Assistance Listing Number: 93.788 Federal Award Identification Number and Year: K4849-02 – 2022, K6479 - 2023 Pass-Through Agency: Washington State Health Care Authority Pass-Through Number(s): K4849-02, K6479 Award Period: September 30, 2020 – September 29, 2022; September 29, 2022 – September 28, 2023 Type of Finding: - Material Weakness in Internal Control over Compliance – Allowable Costs and Activities; Material Noncompliance (Modified Opinion) Criteria or specific requirement: Proper internal controls over time and effort are to be in place in order to ensure payroll costs are properly charged to grants. Condition: Time sheets did not indicate the project/grant the employee worked on for the pay period to support allocation to the grant. For July 2022 through January 2023 payroll costs were charged 100% to either ALN 93.959 or ALN 93.788 and were not allocated based on the employee's time spent working in the programs. For February 2023 through June 2023 payroll costs were allocated to the grants based on the amount of expenses paid on behalf of program participants during the month for items such as rent, groceries, utilities, etc. Questioned costs: Unknown due to inadequate tracking of time. Context: Of the 10 payroll transactions tested for the SOR program, one was properly charged to the grant and supported by time and effort documentation. Time and effort was not properly tracked during the audit period between the SOR and SABG program. Eligibility requirements for the SOR program are more restrictive, thus not all time spent providing services to SABG and SOR participants would meet the allowable costs and activities requirements of the program. Cause: Time and effort between the SOR and SABG programs was not tracked during the audit period to accurately allocate time between the programs. Effect: Payroll costs were not charged to the program based on time and effort. Repeat finding: Not a repeat finding. Recommendation: We recommend time spent on the SOR program be coded to a unique project code in order to ensure time and effort is properly identified and tracked for the program. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: OBHC implemented new payroll software in March 2023. During FY24, staff were trained to directly allocate their time to programs in their electronic timecard. Effective Feb 2024, time and effort reporting was used to allocate salaries to the SOR program. Additionally, the OBHC team is currently working with the HCA in restructuring the rate schedule to incorporate the payroll costs into the direct service rates for the SOR/SABG grants. This effectively removes this issue going forward in FY25 once approved by the HCA. Name(s) of the contact person(s) responsible for corrective action: Patty Brandt Planned completion date for corrective action plan: Feb 2024 & Sep 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2022-06-30

$1,298,193 federal awards expended

FAC accepted this audit on December 15, 2022 — management decision was due June 15, 2023.

2022-002
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During audit procedures performed, we noted three payroll transactions tested included pay dates prior to the beginning period of performance, and the payroll costs were charged to the grant. Questioned Costs: $6,814 Context: During audit procedures performed, we tested one payroll transaction for beginning period of performance testing related to ALN 93.788 and noted the pay period for this transaction began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Of the 9 payroll transactions tested for ALN 93.959 we noted 2 payroll transactions for which the pay period began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Cause: The Organization?s internal controls lacked proper procedures to ensure expenditures were not being charged to the grant if it was not incurred within the period of performance. Effect: The Organization charged expenditures to the grants and was reimbursed for these costs that included payroll costs incurred outside of the contract period of performance. Recommendation: We recommend that the Organization develop a procedure to ensure that payroll transactions are properly allocated based on the dates incurred within the period of performance. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Finding 2022?002 Federal agency: U.S. Department of Health and Human Services Federal program: SOR Recovery Support Services; Substance Abuse Prevention and Treatment Block Grant (SABG) Assistance Listing Numbers: 93.788 and 93.959 Pass-Through Agencies: Washington State Health Care Authority; Beacon Health Options, Inc. Pass-Through Number(s): K4849, K3216 and 1009592.8 Award Period: September 30, 2021 ? September 29, 2022; July 1, 2021 ? June 30, 2022. Type of Finding: Significant Deficiency in Internal Control Over Period of Performance Criteria: Under ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance applicable to the grant. Condition: During audit procedures performed, we noted three payroll transactions tested included pay dates prior to the beginning period of performance, and the payroll costs were charged to the grant. Questioned Costs: $6,814 Context: During audit procedures performed, we tested one payroll transaction for beginning period of performance testing related to ALN 93.788 and noted the pay period for this transaction began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Of the 9 payroll transactions tested for ALN 93.959 we noted 2 payroll transactions for which the pay period began prior to the period of performance beginning date for the grant, and the payroll costs incurred prior to the beginning period of performance date were charged to the grant. Cause: The Organization?s internal controls lacked proper procedures to ensure expenditures were not being charged to the grant if it was not incurred within the period of performance. Effect: The Organization charged expenditures to the grants and was reimbursed for these costs that included payroll costs incurred outside of the contract period of performance. Recommendation: We recommend that the Organization develop a procedure to ensure that payroll transactions are properly allocated based on the dates incurred within the period of performance. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Corrective Action Plan: Okanogan Behavioral HealthCare (OBHC) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The monthly close checklist has been modified to include a payroll transaction process for the September close for this grant. This is the sole grant that requires a second grant closure process. Name of the contact person responsible for corrective action: Patty Branch, Finance Manager Planned completion date for corrective action plan: October 2022 for the September close and grant invoice submission.

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FY 2021-06-30

$1,140,277 federal awards expended

FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.

2021-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

During audit procedures performed, we noted that the Organization doesn't have a specific policy on procurement or suspension and debarment. In addition, the Organization does not have procedures in place to ensure that it complies with federal procurement requirements. Context: There is no updated policy for procurement. Cause: The Organization failed to create and adopt such policies. Effect: incorrect procurement or entering into a contract with a suspended or debarred vendor. Recommendation: We recommend that a procurement and suspension and debarment policy are created in line with Uniform Guidance. Furthermore, we recommend that these policies are approved by the Board. Views of responsible officials: There is no disagreement with the audit finding.

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2021 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program: SOR Recovery Support Services CFDA Number: 93.788 Pass-Through Agency: Washington State Health Care Authority and Beacon Health Options, Inc. Pass-Through Number(s): N/A Award Period: 9/30/2020 ? 9/29/2021 Type of Finding: Significant Deficiency in Internal Control Over Procurement Criteria: Under ?200.318, a non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, ?200.213 states non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During audit procedures performed, we noted that the Organization doesn't have a specific policy on procurement or suspension and debarment. In addition, the Organization does not have procedures in place to ensure that it complies with federal procurement requirements. Context: There is no updated policy for procurement. Cause: The Organization failed to create and adopt such policies. Effect: incorrect procurement or entering into a contract with a suspended or debarred vendor. Recommendation: We recommend that a procurement and suspension and debarment policy are created in line with Uniform Guidance. Furthermore, we recommend that these policies are approved by the Board. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Corrective Action Plan: Okanogan Behavioral HealthCare (OBHC) respectfully submits the following corrective action plan for the year ended June 30, 2021. Audit period: 7/1/2020 ? 6/30/2021 Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Compliance Director will create a procurement and suspension and debarment policy that is in accordance with the requirements established by the Uniform Guidance. Name of the contact person responsible for corrective action: Melanie Bailey, COO Planned completion date for corrective action plan: Draft of procurement policy completed on 5/23/2022.. Board is expected to review and approve this policy at the June 2022 board meeting. .

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FY 2020-06-30

$1,202,653 federal awards expended

FAC accepted this audit on February 13, 2021 — management decision was due August 13, 2021.

2020-003
Cash Management
SIGNIFICANT DEFICIENCY

During audit procedures performed, we noted that there is no review and approval process in place prior to submission of grant draw requests to the granting agency. Further, there are no other internal control processes in place to ensure that grant draws are accurate and properly supported with documentation prior to the draw request. Context: There was no prior review and approval indicated on any of the cash management drawdowns reviewed as part of audit testing. Cause: Inadequate implementation of internal controls over compliance related to cash management. Effect: Lack of proper review and approval could result in incorrect draws and over-expenditure of the grant. Recommendation: We recommend that all grant draw requests are reviewed and approved by an individual separate from the individual preparing the draw request. The review process should include verifying amounts being claimed for reimbursement, and reviewing formulas and calculations for accuracy. This review and approval should occur prior to submission to the granting agency and be formally documented. Views of responsible officials: There is no disagreement with the audit finding.

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2020 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program: Block Grants for Prevention and Treatment of Substance Abuse CFDA Number: 93.959 Pass-Through Agency: Washington State Health Care Authority and Beacon Health Options, Inc. Pass-Through Number(s): N/A Award Period: 4/1/2019 ? 6/30/2020 Type of Finding: Significant Deficiency in Internal Control Over Cash Management Criteria: Management is responsible for developing and maintaining internal controls over cash management include the review and approval of grant draws prior to submission to the granting agency. Condition: During audit procedures performed, we noted that there is no review and approval process in place prior to submission of grant draw requests to the granting agency. Further, there are no other internal control processes in place to ensure that grant draws are accurate and properly supported with documentation prior to the draw request. Context: There was no prior review and approval indicated on any of the cash management drawdowns reviewed as part of audit testing. Cause: Inadequate implementation of internal controls over compliance related to cash management. Effect: Lack of proper review and approval could result in incorrect draws and over-expenditure of the grant. Recommendation: We recommend that all grant draw requests are reviewed and approved by an individual separate from the individual preparing the draw request. The review process should include verifying amounts being claimed for reimbursement, and reviewing formulas and calculations for accuracy. This review and approval should occur prior to submission to the granting agency and be formally documented. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Okanogan Behavioral Healthcare (OBHC) submits the following corrective action plan for the year ended June 30, 2020. Audit period: July 1, 2019 ? June 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Services 2020-003 Block Grants for Prevention and Treatment of Substance Abuse CFDA No. 93.959 Recommendation: We recommend that all grant draw requests are reviewed and approved by an individual separate from the individual preparing the draw request. The review process should include verifying amounts being claimed for reimbursement, and reviewing formulas and calculations for accuracy. This review and approval should occur prior to submission to the granting agency and be formally documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The CFO and Finance Director as of the June 30, 2020 audit date have both since separated from the organization. New CFO, Eric Westerlund, supported by a professional consultant, has strengthened processes and has trained staff on dual control procedures. As of September 30, a new Contracts Manager role was created to enable improved management and control of our various contracts and grants. The Contracts Manager role reports directly to the CFO. As of October 2020 draws, grant billing transitioned from the Finance Director to the Contracts Manager. Grant billings performed by the Finance Director were not reviewed prior to submitting draw requests. Effective with the responsibility transfer and the reporting line to the CFO, grant billing activity and documentation will be reviewed with the CFO prior to the submission of the draw requests with the granting agency. Additionally, month-end closing procedures were enhanced with a ?closing checklist? implemented in November 2020. This process records authorization of draw submissions and their dual review & approval. This will ensure submissions are handled appropriately each month, supported by fully reviewed documentation. Over the last six months, OBHC management has worked closely with the auditors to identify and resolve issues, improve staffing, and improve ongoing procedures. Name(s) of the contact person(s) responsible for corrective action: Eric Westerlund, CFO Planned completion date for corrective action plan: Completed November 2020

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2020-004
Period of Performance
SIGNIFICANT DEFICIENCY

During our period of performance testing, we identified two instances in which the general disbursement selected for testing did not have documentation of proper expense approval prior to payment being made. Context: Proper documentation of review and approval of general disbursements was not documented. Cause: Lack of review and approval the general disbursements appears to be an internal control oversight. Effect: Lack of proper review and approval of disbursements could result in costs being allocated to the grant that are not allowable. Recommendation: We recommend that all invoices are approved by a supervisor knowledgeable of the grant requirements prior to payment by the accounting department. Views of responsible officials: There is no disagreement with the audit finding.

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2020 ? 004 Federal agency: U.S. Department of Health and Human Services Federal program: Block Grants for Prevention and Treatment of Substance Abuse CFDA Number: 93.959 Pass-Through Agency: Washington State Health Care Authority and Beacon Health Options, Inc. Pass-Through Number(s): N/A Award Period: 4/1/2019 ? 6/30/2020 Type of Finding: Significant Deficiency in Internal Control Over Period of Performance Criteria: Proper internal controls over general disbursements include the review and approval of expenditures by a supervisor prior to payment. Condition: During our period of performance testing, we identified two instances in which the general disbursement selected for testing did not have documentation of proper expense approval prior to payment being made. Context: Proper documentation of review and approval of general disbursements was not documented. Cause: Lack of review and approval the general disbursements appears to be an internal control oversight. Effect: Lack of proper review and approval of disbursements could result in costs being allocated to the grant that are not allowable. Recommendation: We recommend that all invoices are approved by a supervisor knowledgeable of the grant requirements prior to payment by the accounting department. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Okanogan Behavioral Healthcare (OBHC) submits the following corrective action plan for the year ended June 30, 2020. Audit period: July 1, 2019 ? June 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Services 2020-004 Block Grants for Prevention and Treatment of Substance Abuse CFDA No. 93.959 Recommendation: We recommend that all invoices are approved by a supervisor knowledgeable of the grant requirements prior to payment by the accounting department. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The CFO and Finance Director as of the June 30, 2020 audit date have both since separated from the organization. New CFO, Eric Westerlund, supported by a professional consultant, has strengthened processes and has trained staff on dual control procedures. As of September 30, a new Contracts Manager role was created to enable improved management and control of our various contracts and grants. The Contracts Manager role reports directly to the CFO. As of October 2020 draws, grant billing transitioned from the Finance Director to the Contracts Manager. Grant billings performed by the Finance Director were not reviewed prior to submitting draw requests. That review would also identify any expense not properly authorized/documented prior to draw submissions. Effective with the responsibility transfer and the reporting line to the CFO, grant billing activity and documentation will be reviewed with the CFO prior to the submission of the draw request with the granting agency. Proper approval on all items will be documented by the approver?s signature and date on the item (or other electronic means). Over the last six months, OBHC management has worked closely with the auditors to identify and resolve issues, improve staffing, and improve ongoing procedures. Name(s) of the contact person(s) responsible for corrective action: Eric Westerlund, CFO Planned completion date for corrective action plan: Completed November 2020

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