Nebraska AIDS Project, Inc.

U.S. Department of Health and Human Services Pass-through Programs from: Nebraska Department of Health and Human Services and the Iowa Department of Health and Human Services HIV Care Formula Grants AL #93.917 Award No. 24X07HA00042, 24X07HA00041, 5884HC14 Award Periods: April 1, 2023 to March 31, 2024 and April 1, 2024 to March 31, 2025 Criteria: Per the terms and conditions of the pass-through entity agreement between the Nebraska Department of Health and Human Services, “client must be HIV positive and documentation (e.g., viral load laboratory results, physician’s verification of HIV status in form of signed letter) substantiating their HIV status must be on file with the contracting/subrecipient organization providing Ryan White Part B funded services.” Additionally, per the terms and conditions of the pass-through entity agreement between the Iowa Department of Health and Human Services, “Client eligibility must be determined within 60 days of initial intake and annually thereafter. Eligibility documentation must include proof of HIV diagnosis, proof of residency, and proof of income.” Condition: For 1 of 25 program participants selected for testing from the State of Nebraska, the participant file was missing documentation of HIV status. For 1 of 13 program participants selected for testing from the State of Iowa, the participant file was missing documentation for the annual recertification. Cause: Adequate internal controls were not in place to ensure compliance with eligibility requirements. Effect: Documentation was not maintained or obtained related to client eligibility which could cause the participant to not be considered eligible and be discharged from the program Questioned Costs: None Context/Sampling: During our audit, we selected a sample of 25 program participants for testing from Nebraska and 13 program participants for testing from Iowa. Repeat Finding from Prior Year: No Recommendation: Management should implement procedures to verify documentation for eligibility is maintained in the files. Additionally, management should implement procedures to ensure completion of the recertification within the timeframe. Views of Responsible Officials: Management agrees with this finding.

2021-004 Internal Controls over Accounts Payable and Allowable Activities and Costs Information on the Federal Program: U.S. Department of Health and Human Services, HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B), Assistance Listing No. 93.917, Passed through the Nebraska Department of Health and Human Services, Grant Agreement No. 20X7CHA36897C3, Award Periods April 1, 2020 through March 31, 2021 and April 1, 2021 through March 31, 2022, and Passed through the Iowa Department of Public Health, Grant Agreement No. 5881HC14 and 5882HC14, Award Periods April 1, 2020 through March 31, 2021 and April 1, 2021 through March 31, 2022. Criteria: 2 CFR ?200.303 requires the Organization to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Organization is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, the Organization?s accounting policies and procedures for accounts payable requires that before the preparation of printed checks, a listing of checks to be issued, and all invoices, attachments, and approvals be reviewed for completeness and accuracy of accounting coding. The Organization did not maintain a system of internal control over disbursements, including those claimed under the Federal awards, with sufficient detail to provide for the review and approval of all disbursements at an individual level. Condition: The Organization did not maintain a system of internal control to provide for the detailed review and approval of costs, including those claimed under the Federal awards. Cause: A breakdown in the Organization?s internal controls over payroll and non-payroll costs did not allow the Organization to sufficiently evidence review and approval of costs, including those claimed under the Federal awards. Effect or Potential Effect: The control deficiency is a material weakness that may have caused the Organization to pay unauthorized, invalid, or unallowable costs, including those claimed under Federal awards. Identification of a Repeat Finding: Repeat finding of 2020-004. Recommendation: The Organization should review its system of internal control over accounts payable to determine improvements that can be made to ensure all disbursements, including payroll and non-payroll costs, are appropriately reviewed and approved at a detailed level prior to payment. The Organization should also incorporate a procedure to evidence the review and approval of the responsible individual. Responsible Official?s Response: Management understands the need to review and approve disbursements and has implemented procedures to provide for the review and approval of all payroll and non-payroll costs at a detailed level by the Executive Director, which will be evidenced by an initial or other documentation.

2020-004 Internal Controls over Accounts Payable and Allowable Activities and Costs Identification Data: U.S. Department of Health and Human Services, HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B), CFDA No. 93.917, Passed through the Nebraska Department of Health and Human Services, Grant Agreement No. 20X7CHA36897C3, Award Periods April 1, 2019 through March 31, 2020 and April 1, 2020 through March 31, 2021, and Passed through the Iowa Department of Public Health, Grant Agreement No. 5880HC14 and 5881HC14, Award Periods April 1, 2019 through March 31, 2020 and April 1, 2020 through March 31, 2021. Criteria: 2 CFR ?200.303 requires the Organization to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Organization is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, the Organization?s accounting policies and procedures for accounts payable requires that before the preparation of printed checks, a listing of checks to be issued, and all invoices, attachments, and approvals be reviewed for completeness and accuracy of accounting coding. The Organization did not maintain a system of internal control over disbursements, including those claimed under the Federal awards, with sufficient detail to provide for the review and approval of all disbursements at an individual level. Condition: The Organization did not maintain a system of internal control to provide for the detailed review and approval of costs, including those claimed under the Federal awards. Cause: A breakdown in the Organization?s internal controls over accounts payable did not allow the Organization to sufficiently evidence review and approval of costs, including those claimed under the Federal awards. Effect or Potential Effect: The control deficiency is a material weakness that may have caused the Organization to pay unauthorized, invalid, or unallowable costs, including those claimed under Federal awards. Recommendation: The Organization should review its system of internal control over accounts payable to determine improvements that can be made to ensure all disbursements, including payroll and non-payroll costs, are appropriately reviewed and approved at a detailed level prior to payment. The Organization should also incorporate a procedure to evidence the review and approval of the responsible individual. Responsible Official?s Response: Management understands the need to review and approve disbursements and has implemented procedures to provide for the review and approval of all payroll and non-payroll costs at a detailed level by the Executive Director, which will be evidenced by an initial or other documentation.

2020-005 Internal Controls over Earmarking Identification Data: U.S. Department of Health and Human Services, HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B), CFDA No. 93.917, Passed through the Nebraska Department of Health and Human Services, Grant Agreement No. 20X7CHA36897C3, Award Periods April 1, 2019 through March 31, 2020 and April 1, 2020 through March 31, 2021. Criteria: The August 2020 OMB Compliance Supplement for the Ryan White HIV/AIDS Program Part B limits the aggregate of expenditures for administrative expenses to 10% of the total amount of grant funds awarded. The Organization?s grant agreement with the State of Nebraska Department of Health and Human Services further allows administrative costs of up to 20% of the award. The Organization does not have a system of internal control over earmarking to allow for tracking of the Organization?s compliance with the administrative cost limit. Condition: The Organization did not maintain a system of internal control to provide for the periodic review and comparison of the Organization?s program costs with the administrative cost limitations of the award. Cause: A lack of internal controls over earmarking did not provide a process for the Organization to actively review and monitor the Organization?s program costs with the requirements of the administrative cost limitations. Effect or Potential Effect: The control deficiency is a significant deficiency that may have allowed the Organization to exceed the administrative costs allowed under the grant award. Recommendation: The Organization should review its system of internal control over earmarking to determine improvements that can be made to ensure the Organization actively monitors its program costs for compliance with the administrative cost limitations. Responsible Official?s Response: Management understands the need to monitor program costs to ensure compliance with the administrative cost requirements. The State of Nebraska Department of Health and Human Services? program invoice provides for the breakdown of costs for administrative activities and direct client services. Management will utilize the invoice subtotals to monitor its compliance with the administrative cost limitations on an aggregate basis during each award period.