Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 200.303 specifies that a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: BHT did not have policies and procedures in place to ensure all the requirements of subrecipient monitoring were being performed. Context: Of the five subrecipients selected for testing (there were seven in the population), we noted that limited subrecipient monitoring procedures were performed. Cause: Policies and procedures were not in place to provide adequate subrecipient monitoring. Effect: BHT could pass through federal funding to subrecipients who do not have the internal policies and controls in place to properly manage the federal funding. Repeat Finding: Yes. Prior year finding 2021-003. Recommendation: We recommend that BHT implements policies and procedures to perform subrecipient monitoring.
Action taken in response to finding: BHT will implement CliftonLarsenAllen LLP?s recommendation to adopt additional policies and procedures to perform subrecipient monitoring. Additionally, In June 2022, BHT retained a CliftonLarsenAllen LLP consultant to perform a grant compliance assessment and provide recommendations for policies and procedures. BHT prepared policies and procedures related to contract management. The new policies and procedure(s) were presented to the BHT Finance Committee and approved by the BHT Board of Directors in December 2022. BHT started the implementation of the policies and procedures in 2023.
2021-003
Condition: Indirect costs were improperly calculated. Questioned Costs: Known: $5,511.61 Likely: $26,002.27 Context: Of the five indirect costs selected for testing (there were 13 in the population), we noted two were improperly calculated. CLA noted that after July 2021 these costs were properly calculated. Cause: Indirect costs were not calculated correctly and the error was not caught during the review process. Effect: BHT has overcharged indirect costs. This reduces the amount of direct funding available for programmatic activities and may result in BHT needing to reimburse the grantor for the overcharged amount. Recommendation: We recommend that BHT ensure that individuals preparing and reviewing the monthly reimbursement requests are appropriately trained and are familiar with the contract requirements for calculating indirect costs.
Views of responsible officials and planned corrective actions: BHT will implement CliftonLarsenAllen LLP's recommendation to adopt additional procedures and training for preparing and reviewing the monthly reimbursement request to ensure correct calculations. BHT will adopt new procedures, and training will be completed by December 31, 2022. The new procedure(s) will be presented to the BHT Finance Committee and approved by the BHT Board of Directors in December 2022. On July 8, 2022, BHT added an Assistant Controller role to provide additional capacity that meets BHT's growing needs. Additionally, in June 2022, BHT retained a CliftonLarsenAllen LLP consultant to perform a grant compliance assessment and provide recommendations for policies and procedures. BHT will prepare and implement policies and procedures related to contract management. The consultants will provide training on the new policies and procedures. This work is expected to be completed by December 31, 2022. The new policies and procedure(s) will be presented to the BHT Finance Committee and approved by the BHT Board of Directors in December 2022.
Condition: BHT did not have policies and procedures in place to ensure all the requirements of subrecipient monitoring were being performed. Context: Of the five subrecipients selected for testing (there were 8 in the population), we noted that limited subrecipient monitoring procedures were performed. Cause: Policies and procedures were not in place to provide adequate subrecipient monitoring. Effect: BHT could pass through federal funding to subrecipients who do not have the internal policies and controls in place to properly manage the federal funding. Recommendation: We recommend that BHT implements policies and procedures to perform subrecipient monitoring.
Views of responsible officials and planned corrective actions: BHT will implement CliftonLarsenAllen LLP's recommendation to adopt additional policies and procedures to perform subrecipient monitoring. On July 8, 2022, BHT added an Assistant Controller role to provide additional capacity that meets BHT's growing needs. Additionally, in June 2022, BHT retained a CliftonLarsenAllen LLP consultant to perform a grant compliance assessment and provide recommendations for policies and procedures. BHT will prepare and implement policies and procedures related to contract management. The consultants will provide training on the new policies and procedures. This work is expected to be completed by December 31, 2022. The new policies and procedure(s) will be presented to the BHT Finance Committee and approved by the BHT Board of Directors in December 2022.
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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