EIN: 550559322
UEI: L4HMRZRGJDM5
Audited by: EIDE BAILLY LLP
Oversight agency: 93 [Department of Health and Human Services]
View federal awards & risk assessment →
Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 2026. 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 October 1, 2026 (28 days from today).
What is a management decision? →During our testing, it was noted that the cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Cause: The Clinic did not have an internal control system designed to ensure that expenditures had been incurred or would be paid within three days of requesting a cash draw on this program. In addition, the Clinic did not have an adequate internal control policy to require the documentation of the cash draw requests’ review and approval. Effect: The lack of adequate policies governing review and approval over the cash draw requests increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context: A nonstatistical sample of four cash draws totaling $385,000 were tested out of six cash draws totaling $560,000. Expenditures for all four cash draws tested were incurred greater than three days after the draw was requested. Repeat Finding from Prior Years: Yes – 2024-003 Recommendation: We recommend the Clinic enhance internal control policies to cash draw requests are reviewed and approved by someone who is familiar with the program requirements and all of that information is retained to ensure that all cash draw requests are correct, meet the requirements of the federal program, and are properly recorded. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.912 Rural Healthcare Services Programs Cash Management Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that the cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Cause: The Clinic did not have an internal control system designed to ensure that expenditures had been incurred or would be paid within three days of requesting a cash draw on this program. In addition, the Clinic did not have an adequate internal control policy to require the documentation of the cash draw requests’ review and approval. Effect: The lack of adequate policies governing review and approval over the cash draw requests increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context: A nonstatistical sample of four cash draws totaling $385,000 were tested out of six cash draws totaling $560,000. Expenditures for all four cash draws tested were incurred greater than three days after the draw was requested. Repeat Finding from Prior Years: Yes – 2024-003 Recommendation: We recommend the Clinic enhance internal control policies to cash draw requests are reviewed and approved by someone who is familiar with the program requirements and all of that information is retained to ensure that all cash draw requests are correct, meet the requirements of the federal program, and are properly recorded. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Health and Human Services Program Name: Rural Healthcare Services Programs Federal Financial Assistance Listing #93.912 Compliance Requirement: Cash Management Finding Summary: The cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days Responsible Individuals: Mary Page Nemcik, Executive Director Corrective Action Plan: The organization has a formal policy surrounding the review and approval of reporting for federal grants. This policy is designed to ensure that the entity has effective internal control over the federal awards and that the entity is managing any federal awards in compliance with federal statutes, regulations and conditions of the federal award. Beginning in July 2025, all allowable expenses and relative supporting documentation to be applied to the RCORP grant are reviewed by the Finance director at month end close and submitted to the Grant Program Manager for review. The PM is responsible for confirming all expenses are categorized correctly, supported by approved time and effort reports and corresponding invoices for monthly expenditures are present. Time and effort logs are then approved by the director of human resources, who also manages payroll for the organization. Once all expenditures are approved by the finance and HR directors and the PM, a request for reimbursement is forward to HRSA for drawdown approval. Once authorization is received from HRSA, the Director of Finance logs onto PMS and requests the drawdown. Any reports that are completed by the Grant Program Manager are reviewed by the Director of Finance before submission and any reports completed by the Director of Finance are reviewed by the Grant Program Manager before submission. Requests for funds are made based on invoices that have already been expensed. Completion Date: July 2025
2024-003
During our testing, it was noted that some key line items in the required federal financial report were not fully supported by underlying documentation. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of reports was properly documented and the reports agreed to the supporting documentation. Effect: The lack of adequate policies governing review and approval over reporting and the supporting documentation program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context/Sampling: One out of one required federal financial report was tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure reports for the federal program are reviewed and approved and all of the supporting documentation is retained to ensure that all reports are correct and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.912 Rural Healthcare Services Programs Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that some key line items in the required federal financial report were not fully supported by underlying documentation. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of reports was properly documented and the reports agreed to the supporting documentation. Effect: The lack of adequate policies governing review and approval over reporting and the supporting documentation program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context/Sampling: One out of one required federal financial report was tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure reports for the federal program are reviewed and approved and all of the supporting documentation is retained to ensure that all reports are correct and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Program Name: Rural Healthcare Services Programs Federal Financial Assistance Listing #93.912 Compliance Requirement: Reporting Finding Summary: During audit testing, it was noted that some key line items in the required federal financial report were not fully supported by underlying documentation Responsible Individuals: Mary Page Nemcik, Executive Director Corrective Action Plan: The organization has a formal policy surrounding the review and approval of reporting for federal grants. This policy is designed to ensure that the entity has effective internal control over the federal awards and that the entity is managing any federal awards in compliance with federal statutes, regulations and conditions of the federal award. Beginning in July 2025, all allowable expenses and relative supporting documentation to be applied to the RCORP grant are reviewed by the Finance director at month end close and submitted to the Grant Program Manager for review. The PM is responsible for confirming all expenses are categorized correctly, supported by approved time and effort reports and corresponding invoices for monthly expenditures are present. Time and effort logs are then approved by the director of human resources, who also manages payroll for the organization. Once all expenditures are approved by the finance and HR directors and the PM, a request for reimbursement is forward to HRSA for drawdown approval. Once authorization is received from HRSA, the Director of Finance logs onto PMS and requests the drawdown. Any reports that are completed by the Grant Program Manager are reviewed by the Director of Finance before submission and any reports completed by the Director of Finance are reviewed by the Grant Program Manager before submission. Requests for funds are made based on invoices that have already been expensed. Completion Date: July 2025
During our testing, it was noted that some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of expenditures and the allocation of expenditures to the federal program was documented. Effect: The lack of adequate policies governing review and approval over expenditures and the allocation of expenditures to the federal program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: $20,598 Context/Sampling: A nonstatistical sample of 40 expenditures were selected for testing, which accounted for $406,494 of $701,412 direct program expenditures. For nine of the 40 expenditures tested, the amount allocated to the program did not agree to supporting documentation and did not contain evidence of a secondary review to verify that expenditures met the terms and conditions of the program and were properly allocated to the program. Repeat Finding from Prior Years: Yes – 2024-004 Recommendation: We recommend the Clinic enhance internal control policies to ensure expenditures and the allocation of expenditures to the federal program are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.912 Rural Healthcare Services Programs Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Material Weakness in Internal Control Over Compliance and Noncompliance not Considered to be Material Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of expenditures and the allocation of expenditures to the federal program was documented. Effect: The lack of adequate policies governing review and approval over expenditures and the allocation of expenditures to the federal program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: $20,598 Context/Sampling: A nonstatistical sample of 40 expenditures were selected for testing, which accounted for $406,494 of $701,412 direct program expenditures. For nine of the 40 expenditures tested, the amount allocated to the program did not agree to supporting documentation and did not contain evidence of a secondary review to verify that expenditures met the terms and conditions of the program and were properly allocated to the program. Repeat Finding from Prior Years: Yes – 2024-004 Recommendation: We recommend the Clinic enhance internal control policies to ensure expenditures and the allocation of expenditures to the federal program are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Health and Human Services Program Name: Rural Healthcare Services Programs Federal Financial Assistance Listing #93.912 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding Summary: Some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. Responsible Individuals: Mary Page Nemcik, Executive Director Corrective Action Plan: In September 2025 the former Controller resigned. At that time the Manager of Accounting was moved into the Director of Finance position and a procedure was put into place for all grants. Invoices are now received and entered by the Accounts Payable Coordinator. Invoices for any grant is uploaded and saved to a folder on a shared drive for the prospective grant and month. Weekly the Director of Finance reviews the general ledgers for the grants, keeping a separate allocation for each grant listing the invoice date, vendor, amount and category. The cost allocation tool automatically calculates the Indirect Cost. This was retroactive to July 2025 as the grant year had not yet been closed out when the personnel changes were made. Completion Date: September 2025
2024-004
FAC accepted this audit on June 17, 2025 — management decision was due December 17, 2025.
During our testing, it was noted that the cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Cause: The Clinic did not have an internal control system designed to ensure that expenditures had been incurred or would be paid within three days of requesting a cash draw on this program. In addition, the Clinic did not have an adequate internal control policy to require the documentation of the cash draw requests’ review and approval. Effect: The lack of adequate policies governing review and approval over the cash draw requests increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context: Four out of four cash draws totaling $625,000 were tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to cash draw requests are reviewed and approved by someone who is familiar with the program requirements and all of that information is retained to ensure that all cash draw requests are correct, meet the requirements of the federal program, and are properly recorded. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Cash Management Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that the cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Cause: The Clinic did not have an internal control system designed to ensure that expenditures had been incurred or would be paid within three days of requesting a cash draw on this program. In addition, the Clinic did not have an adequate internal control policy to require the documentation of the cash draw requests’ review and approval. Effect: The lack of adequate policies governing review and approval over the cash draw requests increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported Context: Four out of four cash draws totaling $625,000 were tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to cash draw requests are reviewed and approved by someone who is familiar with the program requirements and all of that information is retained to ensure that all cash draw requests are correct, meet the requirements of the federal program, and are properly recorded. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Cash Management Finding Summary: The cash draw requests were done on a prospective basis despite the program requiring that cash draw requests must be for expenditures already incurred or that would be paid within three days. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we have implemented procedures to understand program requirements related to cash draws. The Clinic began requesting funds only for expenditures already incurred or that would be paid within three days. Anticipated Completion Date: Ongoing
During our testing, it was noted that some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. The Clinic also calculated their indirect cost rate based on the total grant budget and claimed an equal amount of indirect costs per month instead of calculating the indirect cost rate per direct expenditures for each month. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of expenditures and the allocation of expenditures to the federal program was documented. In addition, the Clinic did not have an internal control process in place to ensure the correct amounts of indirect costs were requested based on the direct costs for the same period. Effect: The lack of adequate policies governing review and approval over expenditures and the allocation of expenditures to the federal program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 15 expenditures were selected for testing, which accounted for $199,720 of $613,623 direct program expenditures. Eight of the expenditures did not contain evidence of a secondary review to verify that expenditures met the terms and conditions of the program and was properly allocated to the program. A nonstatistical sample of 3 expenditures were selected for testing, which accounted for $11,153 of $22,307 indirect program expenditures. None of the expenditures were calculated based off of actual direct costs or contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure expenditures and the allocation of expenditures to the federal program are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. The Clinic also calculated their indirect cost rate based on the total grant budget and claimed an equal amount of indirect costs per month instead of calculating the indirect cost rate per direct expenditures for each month. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of expenditures and the allocation of expenditures to the federal program was documented. In addition, the Clinic did not have an internal control process in place to ensure the correct amounts of indirect costs were requested based on the direct costs for the same period. Effect: The lack of adequate policies governing review and approval over expenditures and the allocation of expenditures to the federal program increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 15 expenditures were selected for testing, which accounted for $199,720 of $613,623 direct program expenditures. Eight of the expenditures did not contain evidence of a secondary review to verify that expenditures met the terms and conditions of the program and was properly allocated to the program. A nonstatistical sample of 3 expenditures were selected for testing, which accounted for $11,153 of $22,307 indirect program expenditures. None of the expenditures were calculated based off of actual direct costs or contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure expenditures and the allocation of expenditures to the federal program are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Finding 2024-004 Federal Agency Name: Department of Health and Human Services Program Name: Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Financial Assistance Listing #93.912 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Finding Summary: Some expenditures were not fully supported by underlying documentation. In addition, some of the expenditures tested did not have documentation of the review and approval of the allocation of the expenditure to the federal program. The Clinic also calculated their indirect cost rate based on the total grant budget and claimed an equal amount of indirect costs per month instead of calculating the indirect cost rate per direct expenditures for each month. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we have implemented procedures to retain expenditure listings and other support for federal awards as well as the related review. The Clinic began retaining expense reconciliations for all Grants. Anticipated Completion Date: July 1, 2024
FAC accepted this audit on August 16, 2024 — management decision was due February 16, 2025.
The Clinic does not have an internal control system designed to ensure the schedule of expenditures of federal awards is complete and accurate. Cause: Auditor assistance with preparation of the schedule is not unusual as the schedule has unique and specialized requirements and preparation is only required when the Clinic meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Clinic would not be able to draft a complete and accurate schedule of expenditures of federal awards without the assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: Yes Recommendation: We recommend management continually be aware of the financial reporting requirements relating to the Clinic’s schedule of expenditures of federal awards and the internal controls that impact financial reporting. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN#550559322 Preparation of Schedule of Expenditures of Federal Awards Significant Deficiency in Internal Control over Compliance - Other Criteria: Proper controls over financial reporting include a system designed to prepare the schedule of expenditures of federal awards and accompanying notes to the schedule of expenditures of federal awards. Condition: The Clinic does not have an internal control system designed to ensure the schedule of expenditures of federal awards is complete and accurate. Cause: Auditor assistance with preparation of the schedule is not unusual as the schedule has unique and specialized requirements and preparation is only required when the Clinic meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Clinic would not be able to draft a complete and accurate schedule of expenditures of federal awards without the assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: Yes Recommendation: We recommend management continually be aware of the financial reporting requirements relating to the Clinic’s schedule of expenditures of federal awards and the internal controls that impact financial reporting. View of Responsible Officials: Management agrees with the finding.
Finding 2023-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN#550559322 Federal Financial Assistance Listing #93.498 Compliance Requirement: Preparation of Schedule of Expenditures of Federal Awards Finding Summary: The Clinic does not have an internal control system designed to ensure the schedule of expenditures of federal awards is complete and accurate. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards and accompanying notes. We requested that our auditors, Eide Bailly LLP, prepared the schedule of expenditures of federal awards and the accompanying notes to the schedule of expenditures of federal awards as a part of their annual audit. We have designated a member of management to review the drafted schedule of expenditures of federal awards and accompanying notes. Anticipated Completion Date: Ongoing
2022-004
During our testing, it was noted that the original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 4, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 4 TIN #550559322. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listing and special report was documented and retained. In addition, the Clinic did not have an internal control policy in place to retain the original expenditure listing used to support the expenditures claimed on the special report. Effect: The lack of adequate policies governing review and approval over the expenditure listing and special report, and the retention of that listing and review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 65 expenditures were selected for testing, which accounted for $128,988 of $1,113,840 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. There was one special report which was tested. Repeat Finding from Prior Years: Yes Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listing, and special report are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, meet the requirements of the federal program, and are properly recorded in the reports required to be submitted to the federal agency. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN#550559322 Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that the original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 4, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 4 TIN #550559322. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listing and special report was documented and retained. In addition, the Clinic did not have an internal control policy in place to retain the original expenditure listing used to support the expenditures claimed on the special report. Effect: The lack of adequate policies governing review and approval over the expenditure listing and special report, and the retention of that listing and review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 65 expenditures were selected for testing, which accounted for $128,988 of $1,113,840 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. There was one special report which was tested. Repeat Finding from Prior Years: Yes Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listing, and special report are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, meet the requirements of the federal program, and are properly recorded in the reports required to be submitted to the federal agency. View of Responsible Officials: Management agrees with the finding.
Finding 2023-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN#550559322 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Finding Summary: The original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 4, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 4 TIN #550559322. Responsible Individuals: Kayla Trent, Finance Director Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we have implemented procedures to retain expenditure listings and other support for federal awards as well as the related review. The Clinic began retaining expense reconciliations for all Grants. Anticipated Completion Date: July 1, 2024
2022-005
FAC accepted this audit on June 14, 2024 — management decision was due December 14, 2024.
The Clinic does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal. As auditors, we were requested to draft the schedule of expenditures of federal awards. Cause: Auditor assistance with preparation of the schedule is not unusual as the schedule has unique and specialized requirements and preparation is only required when the Clinic meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Clinic would not be able to draft a complete and accurate schedule of expenditures of federal awards without the assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No Recommendation: We recommend management continually be aware of the financial reporting requirements relating to the Clinic’s schedule of expenditures of federal awards and the internal controls that impact financial reporting. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 2 TIN#4550559322 Department of Homeland Security Federal Assistance Listing #97.036 COVID‐19 Disaster Grants – Public Assistance Preparation of Schedule of Expenditures of Federal Awards Material Weakness in Internal Control over Compliance ‐ Other Criteria: Proper controls over financial reporting include a system designed to prepare the schedule of expenditures of federal awards and accompanying notes to the schedule of expenditures of federal awards. Condition: The Clinic does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal. As auditors, we were requested to draft the schedule of expenditures of federal awards. Cause: Auditor assistance with preparation of the schedule is not unusual as the schedule has unique and specialized requirements and preparation is only required when the Clinic meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Clinic would not be able to draft a complete and accurate schedule of expenditures of federal awards without the assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No Recommendation: We recommend management continually be aware of the financial reporting requirements relating to the Clinic’s schedule of expenditures of federal awards and the internal controls that impact financial reporting. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Health and Human Services Program Name: COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 2 TIN#4550559322 Federal Financial Assistance Listing #93.498 Federal Agency Name: Department of Homeland Security Program Name: COVID‐19 Disaster Grants – Public Assistance Federal Financial Assistance Listing #97.036 Compliance Requirement: Preparation of Schedule of Expenditures of Federal Awards Finding Summary: The Clinic does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal. We requested our auditors, Eide Bailly LLP, to draft the schedule of expenditures of federal awards. Auditor assistance with preparation of the schedule is not unusual as the schedule has unique and specialized requirements and preparation is only required when the Clinic meets a specified threshold of federal expenditures. Responsible Individuals: David Meadows, Interim CFO Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards and accompanying notes. We requested that our auditors, Eide Bailly LLP, prepared the schedule of expenditures of federal awards and the accompanying notes to the schedule of expenditures of federal awards as a part of their annual audit. We have designated a member of management to review the drafted schedule of expenditures of federal awards and accompanying notes. Anticipated Completion Date: Ongoing
During our testing, it was noted that the original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 2, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 2 TIN #4550559322. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listing and special report was documented and retained. In addition, the Clinic did not have an internal control policy in place to retain the original expenditure listing used to support the expenditures claimed on the special report. Effect: The lack of adequate policies governing review and approval over the expenditure listing and special report, and the retention of that listing and review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 expenditures were selected for testing, which accounted for $100,891 of $157,739 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. There was one special report which was tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listing, and special report are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, meet the requirements of the federal program, and are properly recorded in the reports required to be submitted to the federal agency. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 2 TIN#4550559322 Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that the original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 2, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 2 TIN #4550559322. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listing and special report was documented and retained. In addition, the Clinic did not have an internal control policy in place to retain the original expenditure listing used to support the expenditures claimed on the special report. Effect: The lack of adequate policies governing review and approval over the expenditure listing and special report, and the retention of that listing and review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 expenditures were selected for testing, which accounted for $100,891 of $157,739 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. There was one special report which was tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listing, and special report are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, meet the requirements of the federal program, and are properly recorded in the reports required to be submitted to the federal agency. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Health and Human Services Program Name: COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 2 TIN#4550559322 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Finding Summary: The original expenditure listing which would have included the review of the expenditure listing, was not retained. As a part of the single audit, the Clinic recreated the expenditure listing to support the expenditures reported on the special report submitted to the Department of Health and Human Services for Period 2, however there was no control in place to retain the original documentation of the determination of expenditures and their related review. In addition, there was no retained documentation of the review and approval of the Clinic’s special report submitted to the Department of Health and Human Services for Period 2 TIN #4550559322. Responsible Individuals: David Meadows, Interim CFO Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we will implement procedures to retain expenditure listings and other support for federal awards as well as the related review. Anticipated Completion Date: Ongoing
During our testing, it was noted that the review and approval of the expenditure listings was not retained. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listings was documented and retained. Effect: The lack of adequate policies governing review and approval over the expenditure listings increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 42 of 209 expenditures were selected for testing, which accounted for $120,934 of $346,290 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listings are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Homeland Security Federal Assistance Listing #97.036 COVID‐19 Disaster Grants – Public Assistance Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303 (a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Condition: During our testing, it was noted that the review and approval of the expenditure listings was not retained. Cause: The Clinic did not have an internal control policy in place to ensure the review and approval of the expenditure listings was documented and retained. Effect: The lack of adequate policies governing review and approval over the expenditure listings increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 42 of 209 expenditures were selected for testing, which accounted for $120,934 of $346,290 direct program expenditures. None of the expenditures contained evidence of a secondary review to verify that expenditures met the terms and conditions of the program. Repeat Finding from Prior Years: No Recommendation: We recommend the Clinic enhance internal control policies to ensure the expenditure listings are reviewed and approved and all of that information is retained to ensure that all payments are necessary, correct, and meet the requirements of the federal program. View of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Homeland Security Program Name: COVID‐19 Disaster Grants – Public Assistance Federal Financial Assistance Listing #97.036 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Finding Summary: The review and approval of the expenditure listing was not retained. Responsible Individuals: David Meadows, Interim CFO Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we will implement procedures to retain expenditure listings and other support for federal awards as well as the related review. Anticipated Completion Date: Ongoing
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