Finding 2025-001 – Internal Control Deficiency and Noncompliance over Indirect Cost Rates Repeat finding: Yes – Prior year finding 2024-003 Identification of the federal program: Federal grantor: United States Department of Health and Human Services (HHS) Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.403 costs must be allowable; 2 CFR 200.405 allocable; and indirect costs must follow 2 CFR 200.414 and Appendix IV to Part 200 (nonprofit rate determination). Entities without a current negotiated rate may elect the de minimis rate (2 CFR 200.414(f)). HHS codified these requirements at 45 CFR Part 75 for periods through September 30, 2025 and effective October 1, 2025, HHS adopted 2 CFR Part 200 directly, with HHS-specific provisions relocated to 2 CFR Part 300. Condition: The Organization applied and included an expired provisional indirect cost rate in its HHS grant application and budgets. HHS approved the application and budgets; however, the rate in use was not current and the Organization had no active negotiated indirect cost rate agreement (NICRA). Subsequent to year end, in March 2026, the Organization submitted a NICRA proposal to HHS Cost Allocation Services. The Organization was informed by HHS that they may continue to use the provisional rate until a new rate agreement is issued, with an understanding any adjustments identified during the review process will be incorporated into future fixed rates and any applicable carryforward amounts. Cause: Lapse in monitoring and renewing the negotiated indirect cost rate. Effect or potential effect: Risk of noncompliance with cost principles and potential unallowable indirect cost recoveries if the expired rate differs from an approved current rate. Questioned costs: Undetermined. The variance between the expired rate and an allowable rate was not calculated. Recommendation: Continue the application process started in March 2026 to obtain an approved NICRA from the cognizant agency (HHS) and apply it prospectively and, if required, retroactively. Implement controls to track rate expirations and require documented verification of the current rate before grant applications, budget submissions, and draw requests. Views of responsible officials: Management concurs with the recommendation. See Management’s Corrective Action Plan.
Corrective Action Plan: Management is in the process of working with HHS to renew the Provisional Rate agreements. The anticipation is that the agreement will be completed by the end of 2026. Anticipated Completion Date: December 31, 2026
2024-003
Identification of the federal program: Federal grantor: United States Department of Health and Human Services (HHS) Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.403 costs must be allowable; 2 CFR 200.405 allocable; and indirect costs must follow 2 CFR 200.414 and Appendix IV to Part 200 (nonprofit rate determination). Entities without a current negotiated rate may elect the 10% de minimis rate (2 CFR 200.414(f)). HHS adopts these requirements at 45 CFR Part 75. Condition: The organization applied and included an expired provisional indirect cost rate in its HHS grant application and budgets. HHS approved the application and budgets; however, the rate in use was not current and the Organization had no active negotiated indirect cost rate agreement (NICRA). Cause: Lapse in monitoring and renewing the negotiated indirect cost rate. Effect or potential effect: Risk of noncompliance with cost principles and potential unallowable indirect cost recoveries if the expired rate differs from an approved current rate. Questioned costs: Undetermined. The variance between the expired rate and an allowable rate was not calculated. Recommendation: Either (1) obtain an updated NICRA from the cognizant agency (HHS) and apply it prospectively and, if required, retroactively. Implement controls to track rate expirations and require documented verification of the current rate before budget submissions and draw requests. Views of responsible officials: Management occurs with the recommendation. See Management’s Corrective Action Plan.
Corrective Action Plan: Management is in the process of working with HHS to renew the Provisional Rate agreements. The anticipation is that the agreement will be completed by the end of 2025. Anticipated Completion Date: December 31, 2025
Finding 2023-002 – Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” In order for expenditures to be allowable under federal awards, 2 CFR 200.403(a) provides that costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the cost principles. 2 CFR 200.403(g) further provides that costs must be adequately documented. Condition: Management did not have adequately designed internal controls throughout the year over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Section III – Federal Award Findings and Questioned Costs (continued) Cause: Due to the timing of identifying the internal control finding during the 2022 audit, management was not able to timely implement effective internal controls for the entire period under audit for 2023. For certain expenditures, management did not adequately retain invoice or receipt support for non-payroll direct expenditures. Effect or potential effect: Ineffective internal controls could result in expenses being charged to the federal program that are not allowed or are outside the period of performance. Questioned costs: $610. Questioned costs were calculated as the costs without support for the expenditure. Context: Prior to October 15, 2023, payroll controls were designed where the Executive Director reviewed time sheets of the employees working on the program; however, no one reviewed the time submitted by the Executive Director, and if the Executive Director was not available to review the employees’ time sheets, a third-party payroll servicer approved the time. The third-party servicer did not have firsthand knowledge of the activities of each employee. Because the internal controls prior to October 15, 2023, were not designed effectively, we did not test controls over payroll expenditures as they were not in place throughout the audit period. For direct expenses, internal requisitions are to be approved by either the Executive Director or the Assistant Program Director if under $5,000 and by the Executive Director if over $5,000 prior to AdviseWell, Inc. entering into a transaction. Because the internal controls were not implemented timely, we did not test controls surrounding direct expenses. We selected 40 nonpayroll expenditures totaling $13,590 from total nonpayroll expenditures of $590,516 to test allowability, noting that for three selections totaling $610, documentation was not retained to evidence the existence and allowability of the expenditure. For indirect expenses and fringe benefits, the Executive Director calculates the amount and requests reimbursement from the federal program. There was no independent review of the Executive Director’s calculations prior to submitting the request for reimbursement throughout the period under audit. Management asserts that it has internal controls in place to ensure that allowable expenditures are charged to the federal programs within the period of performance. Management did not retain documentation to evidence the internal controls over its review of expenditures to ensure they were within the period of performance. Because evidence of the controls was not retained for the period of performance throughout the entire audit period, we did not test internal controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-001. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls to ensure expenses charged to the federal program are appropriately reviewed and approved by an individual knowledgeable of the program requirements, reviewed prior to entering into the expenditure, and charged within the period of performance. Management should maintain effective segregation of duties. Management should retain invoice or receipt support for all expenditures. View of responsible officials: Management agrees with the finding. Internal controls were enhanced in October 2023 to begin retaining documentation to evidence the controls. Additionally, management will implement internal controls surrounding retaining evidence of expenditures.
Finding 2023-002: Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: Management did not have adequately designed internal controls in place over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-01 finding, to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated. In addition, following the October 2023 implementation, care will be taken to ensure that invoices for vendors using electronic invoicing systems will be downloaded in a timelier manner to ensure electronic invoices do not expire within those systems. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023
2022-001
Finding 2023-003 – Internal Control Deficiency Cash Management Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was no evidence throughout the audit period of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell, Inc. Cause: Controls were not designed to properly ensure the monthly cash drawdowns were complete and accurate and based on expenses that were paid for by AdviseWell, Inc. Effect or potential effect: Inaccurate requests for reimbursement could occur. Questioned costs: None. Context: A monthly profit and loss statement is generated for each grant within the program. This monthly statement is used to make the monthly request for reimbursement. There was no documentation evidencing that the monthly profit and loss statement was reviewed. Additionally, there was no process in place to ensure that the expenditures have been paid for prior to requesting reimbursement, and in certain instances, the final profit and loss statements were not used. Management performed a reconciliation for amounts requested for reimbursement to the final expenditure detail on the profit and loss statements and noted that, ultimately, actual expenditures of the program exceeded the request for reimbursement. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-002. Recommendation: AdviseWell, Inc. should implement internal controls to ensure requests for reimbursement are based upon final expenses and that any inputs used in the request for reimbursement are reviewed and evidence of that review is retained. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 to retain documentation of the review. Additional controls will be implemented to ensure cash draws are based upon final expenses paid for by AdviseWell, Inc.
Finding 2023-003: Internal Control Deficiency Cash Management Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: There is no evidence of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-02 finding, to ensure drawdowns are made on expenses paid for by AdviseWell and not on unpaid obligated funds before proceeding by having a secondary review by appropriate staff. Documentation will be maintained to support those payments preceded drawdowns and secondary review has been completed. Management will ensure all duties are appropriately segregated. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023
2022-002
Finding 2023-004 – Internal Control Deficiency Reporting Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The individual who prepares the SF-425 report was the same individual who reviewed and submitted the reports. Cause: Controls were not designed effectively throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission. Effect or potential effect: Reports could reflect inaccurate information. Questioned costs: None. Context: Because there was not appropriate segregation of duties throughout the audit period, we did not test internal controls over reporting. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-003. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission to ensure reports are complete and accurate. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 whereby the person preparing the reports is independent of the person reviewing the reports.
Finding 2023-004: Internal Control Deficiency Reporting Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The same individual that prepares the SF-425 report, was the same individual who reviewed and submitted the reports. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-03 finding, to ensure that once the SF-425 report is completed, someone from the accounting department verifies the funds being reported are correct and appropriate. Documentation will be maintained to support the review process. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023
2022-003
Finding 2023-005 – Internal Control Deficiency and Noncompliance Over Procurement Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) – General procurement standards states: “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 – Methods of procurement to be followed states: ”The non-Federal entity must have and use documented procurements procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded.” Title 2, Subtitle A, Chapter II, Part 200, Subpart C, 200.214 – Suspension and debarment states: “Non-Federal entities are subject to the non-procurement debarment and suspension regulations that 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: AdviseWell, Inc. did not have internal controls in place throughout the audit period to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price or sole source justification if warranted. Additionally, management did not have evidence of internal controls being in place throughout the audit period to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell, Inc. did not have or use documented procurements procedures throughout the audit period. Cause: Management did not have effective internal controls in place throughout the audit period over the compliance requirement as stated in the criteria section above. Effect or potential effect: Procurements were not supported by effective internal controls and could potentially include unreasonable prices or missing documentation to support the procurements made. If suspension and debarment searches are not conducted, the organization could contract with vendors that are suspended or debarred. Lack of written policies and procedures is out of compliance with the federal requirements and could lead to disallowed procurements. Questioned costs: $80,082. Questioned costs were determined based on the expenditures of the procurements. Context: For five procurements selected for testing totaling $80,082 out of a total population of procurements of $145,646, required documentation was not available supporting the history of the procurement, including rationale for sole source selection. As the written procurement policy was not in place throughout the year and/or documentation of debarment searches on vendors was not maintained throughout the year, we were unable to test these controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-004. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to ensure procurements are in accordance with the federal guidelines. AdviseWell, Inc. should search for suspension and debarment prior to entering into a procurement transaction and retain documentation that the search was conducted prior to entering into the transaction. AdviseWell, Inc. should periodically search recurring vendors for suspension and debarment and retain documentation to support that the search was conducted. View of responsible officials: Management agrees with the finding. A procurement policy was established in October 2023 in accordance with the federal requirements, and documentation for each procurement was retained subsequent to October 2023. Management began retaining documentation that searches were conducted for vendors for suspension and debarment prior to entering into the procurement and on a periodic basis for recurring vendors.
Finding 2023-005: Internal Control Deficiency and Noncompliance Over Procurement Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: AdviseWell, Inc. did not have internal controls in place throughout the audit period to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price or sole source justification if warranted. Additionally, management did not have evidence of internal controls being in place throughout the audit period to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell, Inc. did not have or use documented procurements procedures throughout the audit period. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-04 finding, to ensure that sufficient documentation of history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection of, and the basis for contract price; ensure vendors are not suspended or debarred prior to entering into the procurement process; and document these procurement procedures with an annual review of these with staff. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023
2022-005
Finding 2022-001 ? Internal Control Deficiency over Activities Allowed/Allowable Costs Principles, Period of Performance Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: AdviseWell did not have adequately designed internal controls in place over expenses charged to the federal program. Cause: Management did not have effective internal controls in place Effect or potential effect: Ineffective internal controls could result in expenses being charged to the federal program that are not allowed or are outside the Period of Performance. Questioned Costs: None. Context: Payroll controls are designed where the Executive Director reviews time sheets of the employees working on the program, however, no one reviews the time submitted by the Executive Director and if the Executive Director is not available to review the employees timesheets, a third-party payroll servicer approves the time. The third-party servicer does not have first-hand knowledge of the activities of each employee. Because the internal controls were not designed effectively, we did not test controls surrounding payroll. For direct expenses, internal requisitions are to be approved by either the Executive Director or the Assistant Program Director if under $5,000 and if over $5,000 by the Executive Director prior to the Organization entering into a transaction. For 20 out of 40 transactions selected for testing, the requisition was approved after entering into the transaction. Because the internal controls were not designed effectively, we did not test controls surrounding direct expenses. For indirect expenses and fringe benefits, the Executive Director calculates the amount and requests reimbursement from the federal program. There is no independent review of the Executive Director?s calculations prior to submitting the request for reimbursement. Management asserts that it has internal controls in place to ensure that expenditures are charged to the federal programs within the period of performance. AdviseWell did not retain documentation to evidence the internal controls over their review of expenditures to ensure they were within the period of performance. Because documentation was not retained for Period of Performance, we could not test internal controls. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: AdviseWell should develop and implement effective internal controls to ensure expenses charged to the federal program are appropriately reviewed and approved by an individual knowledgeable of the program requirements, reviewed prior to entering into the expenditure, and charged within the period of performance. AdviseWell should maintain effective segregation of duties. View of Responsible Officials: Management agrees with the finding. Internal controls will be implemented to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated.
Finding 2022-001: Internal Control Deficiency over Activities Allowed/Allowable Costs and Period of Performance Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: Management did not have adequately designed internal controls in place over expenses charged to the federal program. Corrective Action Plan: Internal controls will be implemented to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023
Finding 2022-002 ? Internal Control Deficiency Cash Management Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no evidence of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell. Cause: Controls were not designed to properly to ensure the monthly cash draw downs were complete and accurate and based on expenses that were paid for by AdviseWell. Effect or potential effect: Inaccurate requests for reimbursement could occur. Questioned Costs: None. Context: A monthly profit and loss statement is generated for each grant within the program. This monthly statement is used to make the monthly request for reimbursement. There is no documentation evidencing that the monthly profit and loss statement is reviewed. Additionally, there is no process in place to ensure that the expenditures have been paid for prior to requesting reimbursement. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: AdviseWell should implement internal controls to ensure expense are paid for prior to requesting reimbursement and that any inputs used in the request for reimbursement are reviewed and evidence of that review is retained. View of Responsible Officials: Management agrees with the finding. Controls will be implemented and documentation retained to ensure cash management drawdowns are complete and accurate and based upon expenses paid for by the Organization.
Finding 2022-002: Internal Control Deficiency Cash Management Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: There is no evidence of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell. Corrective Action Plan: Internal controls will be implemented to ensure drawdowns are made on expenses paid for by AdviseWell and not on unpaid obligated funds before proceeding by having a secondary review by appropriate staff. Documentation will be maintained to support those payments preceded drawdowns and secondary review has been completed. Management will ensure all duties are appropriately segregated. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023
Finding 2022-003 ? Internal Control Deficiency Reporting Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There are no internal controls in place to ensure that reports that are submitted are complete and accurate. The same individual that prepares the SF-425 report, is the same person that reviews and submits the reports. Cause: Controls were not designed to properly segregate duties whereby some independent of the preparer is reviewing the reports prior to submission. Effect or potential effect: Reports could reflect inaccurate information. Questioned Costs: None. Context: Because there was not appropriate segregation of duties, we could not test internal controls over Reporting. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: AdviseWell should develop and implement effective internal controls to properly segregate duties whereby some independent of the preparer is reviewing the reports prior to submission. View of Responsible Officials: Management agrees with the finding. Controls will be implemented whereby the person preparing the reports is independent of the person reviewing the reports.
Finding 2022-003: Internal Control Deficiency Reporting Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: There are no internal controls in place to ensure that reports that are submitted are complete and accurate. The same individual that prepares the SF-425 report, is the same person that reviews and submits the reports. Corrective Action Plan: Internal controls will be implemented to ensure that once the SF-425 report is completed, someone from the accounting department will verify funds being reported are correct and appropriate. Documentation will be maintained to support the review process. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023
Finding 2022-004 ? Internal Control Deficiency and Noncompliance Over Procurement Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program Name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) ? General procurement standards states: The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 ? Methods of procurement to be followed ? the non-Federal entity must have and use documented procurements procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases ? (i) small purchase procedures ? the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods ? when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 200.319. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines appropriate? (1) sealed bids ? a procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price; (2) proposals ? a procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that 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: AdviseWell did not have internal controls in place to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, management did not have evidence of internal controls being in place to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell does not have and use documented procurements procedures. Cause: Management did not have effective internal controls in place over the compliance requirement as stated in the criteria section above. Effect or potential effect: Procurements were not supported by effective internal controls and could potentially include unreasonable prices or missing documentation to support the procurements made. If suspension and debarment searches are not conducted, the organization could contract with vendors that are suspended or debarred. Lack of written policies and procedures is out of compliance with the federal requirements and could lead to disallowed procurements. Questioned Costs: None. Context: For five procurements selected for testing, not all required documentation was available supporting the history of the procurement. As there is no written procurement policy or retained documentation of debarment searches performed on vendors prior to entering into a procurement transaction, we were unable to perform tests on these controls. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: AdviseWell should develop and implement effective internal controls to ensure procurements are in accordance with the federal guidelines, including creating a purchasing policy that contains the specified requirements and retaining documentation of adherence to the purchasing policy and the federal guidelines. AdviseWell should conduct searches for suspension and debarment prior to entering into a procurement transaction and retain documentation that the search was conducted prior to entering into the transaction. AdviseWell should periodically search recurring vendors for suspension and debarment and retain documentation to support that the search was conducted. View of Responsible Officials: Management agrees with the finding. A procurement policy will be established that is in accordance with the federal requirements and documentation for each procurement will be retained. Management currently searches vendors for suspension and debarment, but will retain evidence that the searches were conducted prior to entering into the procurement or on a periodic basis for recurring vendors.
Finding 2022-004: Internal Control Deficiency and Noncompliance Over Procurement Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: AdviseWell did not have internal controls in place to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, management did not have evidence of internal controls being in place to document that vendors were not suspended or debarred prior to entering a procurement transaction. AdviseWell does not have and use documented procurements procedures. Corrective Action Plan: Internal controls will be implemented to ensure that sufficient documentation of history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection of, and the basis for contract price; ensure vendors are not suspended or debarred prior to entering into the procurement process; and document these procurement procedures with an annual review of these with staff. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023
2019-001 Timely Submission of Audit Reports Criteria: Under the Uniform Guidance, the Organization is required to submit the annual audit reporting package and Data Collection Form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors? reports or nine months after the end of the audit period. In March 2021, the Office of Management and Budget issued Memorandum M-21-20, which states that awarding agencies should allow recipients and subrecipients with fiscal year ends through June 30, 2021, that have not yet filed their single audits with the Federal Audit Clearinghouse to delay the completion and submission of the single audit reporting package to six months beyond the normal due date. As the Organization?s normal due date was September 30, 2020, the allowed extension was through March 31, 2021. Condition: The Organization did not meet the March 31, 2021 deadline for reporting to the Federal Audit Clearinghouse. Cause: The Organization?s financial statements in accordance with U.S. generally accepted accounting principles were not completed on a timely basis. Timeliness of financial reporting was impacted by a significant transaction occurring near the end of the Organization?s fiscal year. Accordingly, management?s focus was on the effects of that transaction and recording its impact in the financial statements. Effect: The Organization is not in compliance with the Uniform Guidance with respect to timeliness of reporting. Recommendation: The Organization should ensure that year-end procedures are completed on a timely basis to allow sufficient time for the auditor to complete audit procedures in accordance with Government Auditing Standards, and for timely filing of the audit reporting package and the Data Collection Form with the Federal Clearinghouse.
Responsible person: Director of Accounting Action: Effective immediately all required single audits will be initiated within the specified timeframe following the end of the audit period. The final audit report will be submitted to the Federal Clearinghouse within nine months of the end of the audit period. Expected resolution/completion date: 9/1/2021
2019-002 Procurement and Suspension and Debarment U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 93.048 Senior Medicare Patrol Project 2018-2019 Award Year 90MPPG0024-01-00, 90MPPG0023-01-00, 90MPPG0049-01-00, 90MPPG0024-02-00, 90MPPG0023-02-00, 90MPPG0049-02-01 Criteria: The Uniform Guidance federal regulations were fully effective as of December 26, 2017. The regulations (200.320) require, among other things, that procurement for small purchases of goods and services in an amount between the $10,000 to $250,000, follow the small purchase procedures and obtain an adequate number of prices\quotes be obtained. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) by checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non- Federal entity, all contracts made by the non-Federal award entity Federal award must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the non-federal entity including the manner by which it will be effected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of ''federally assisted construction contract'' in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, ''Equal Employment Opportunity'' (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, ?'Amending Executive Order 11246 Relating to Equal Employment Opportunity,? and implementing regulations at 41 CFR part 60, '?Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor.?C.) Debarment and Suspension (Executive Orders 12549 and 12689)?A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), ``Debarment and Suspension.?? The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, two vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. These two vendors provided services to the Organization during year ended December 31, 2019. Compliance testing focused on the proper awarding of the vendor contracts to determine compliance with the procurement regulations. The two vendor payments totaled $49,551 during the fiscal year ended December 31, 2019. No evidence was provided to demonstrate that quotes and prices were obtained for these two vendors as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that the two vendors were appropriately checked for suspension and debarment. Cause: Personnel administering the grants did not execute and enforce the revised purchasing policy containing the new Uniform Guidance requirements, nor was there documented evidence of the procurement policy having been adhered to. Effect: The Organization is not in compliance with the requirements of the Uniform Guidance Procurement regulations. Questioned Costs: Not determined. Universe/ Population Size: The total universe considered to be all vendors of the Senior Medicare Patrol Project whose transactions for the year ended December 31, 2019 exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the universe. Based on these requirements, the total universe is two vendors totaling $49,551. This is also considered the population size. Sample Size: The total universe/population size of two vendors was selected for testing. Recommendation: We recommend that the Organization review and revise policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. Additionally, written documentation should be kept on file to support the Organization?s compliance with procurement policies and procedures. Repeat Finding: No.
Corrective Action for Procurement Pricing: Responsible person: Director of Operations Action: Effective immediately all planned purchases exceeding $10,000 within the audit period for any one vendor or for any aggregate goods or services will be proceeded by the Director of Operations or delegee thereof obtaining three (3) competitive bids or quotes prior to any purchases being made. The Director of Operations or delegee will request authorization from the Chief of Staff or an approved delegee to make a purchase from any vendor or for any goods or services whose aggregate planned purchases exceed $10,000 within the audited period. The Chief of Staff will verify that 3 competitive bids have been obtained prior to authorizing any purchase from a vendor whose planned purchases exceed $10,000 within the audit period. The Chief of Staff will receive from the Director of Operations or delegee 3 competitive bids prior to authorizing any purchase from any vendor or for any goods or services whose aggregate planned purchases exceed $10,000 within the audited period. The results of the bids will be kept on file and will be readily available for audit. Expected resolution/completion date: 9/1/2021 Corrective Action for Checking for Exclusions or Debarment: Responsible person: Director of Accounting Action: Effective immediately, the accounts payable accountant or personnel appointed by the Director of Accounting will check all vendors receiving federal grant funding for exclusion or debarment using the Excluded Parties List System in the System for Award (SAM). All new vendors must be checked for exclusion or debarment prior to payment being made to the new vendor. The accounting department will maintain a current listing of all applicable vendors and their respective exclusion or debarment status. Expected resolution/completion date: 9/1/2021
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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