Gay City Health ProjectNon-Profit

Finding 2023-001 Material weakness in internal controls over compliance and instances of noncompliance related to allowable costs/cost principles compliance requirements. Federal Agency: Department of Health and Human Services (HHS) Pass-Through: State of Washington Department of Health (DOH) Program Title: HIV Prevention Activities Health Department Assistance Listing Number: 93.940 Award Number: CBO27200; CBO28119 Award Period: July 01, 2022 through August 31, 2023 and July 01, 2023 through December 31, 2023 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart E ‐ Cost Principles, Section 200.405 requires that a non-federal entity allocate costs based on the benefits received and costs that benefit both the federal award and other work of the non-federal entity are distributed in proportions that may be approximated using reasonable methods. Condition/Context for Evaluation During our testing of allowable costs, we noted that the non-federal entity applied costs for bonuses, insurance, and the audit fee to the federal program without performing an allocation of the costs to the program and others based on the proportional benefit. Cause The Organization's management was not aware of the allocation requirements of 2 CFR section 200.405. Effect or Potential Effect The Organization did not apply the Uniform Guidance 2 CFR in the allocation of bonuses, insurance, and audit fees resulting in questioned costs. Questioned Costs $29,512 Repeat Finding No. Recommendation We recommend the Organization implement measures to ensure that its allocation methodology follow the allocability requirements of Subpart E in 2 CFR Part 200. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services (HHS) Pass-Through: State of Washington Department of Health (DOH) Program Title: HIV Prevention Activities Health Department Assistance Listing Number: 93.940 Award Number: CBO27200; CBO28119; 10248 PREV Award Period: July 01, 2022 through August 31, 2023; July 01, 2023 through December 31, 2023; April 01, 2023 through March 31, 2024 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Sections 200.318 through 200.320, require that a non-federal entity have documented procurement procedures that provide for full and open competition and follow the procurement methods required by Subpart D of 2 CFR Part 200. Condition/Context for Evaluation Although the Organization has a procurement policy, the policy does not cover the requirements in Subpart D which include the thresholds for micro-purchase awards, small purchases, and formal procurement methods such as sealed bids, proposals, and noncompetitive procurement. Nor does the policy cover solicitation procedures for procurements. Cause The Organization's procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Effect or Potential Effect The absence of a policy that fully conforms to the Uniform Guidance does not assure open and free competition among suppliers. Questioned Costs None.   Repeat Finding No. Recommendation We recommend the Organization implement measures to ensure that its procurement policy reflect applicable requirements in 2 CFR Part 200 Subpart D. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-003 Significant deficiency in internal control over compliance with the level of effort requirements applicable to the major program. Federal Agency: Department of Health and Human Services (HHS) Pass-Through: State of Washington Department of Health (DOH) Program Title: HIV Prevention Activities Health Department Assistance Listing Number: 93.940 Award Number: CBO27200; CBO28119 Award Period: July 01, 2022 through August 31, 2023 and July 01, 2023 through December 31, 2023 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Sections 200.301 and 200.329, require that a non-federal must measure and report on performance progress when the federal awards includes specific program goals, indicators, targets, baseline data, data collection, or expected outcomes with an expected timeline for accomplishment. The non-federal entity is responsible for oversight of the operations of the federal award supported activities and must monitor its activities under Federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Condition/Context for Evaluation The federal awards tested require that for each 1.0 FTE dedicated to this service category, 100 annual PrEP/prevention navigation clients should be served and registered in Provide. The contractor will enter all client-level data in Provide. During our testing, we noted that the Organization was not monitoring this metric. Cause The Organization’s management was not aware of their responsibility to monitor against the level of effort requirement stated in the grant agreement. Effect or Potential Effect Without proper monitoring, the Organization may not meet the requirement specified in the federal award. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Organization implement internal control processes to ensure compliance with the program’s level of effort requirements. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.