MEDICAL TEAMS INTERNATIONAL, INC

Criteria or specific requirement: Per the 2024 OMB Compliance Supplement, "A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h))." Allowable costs must meet the standards set forth in 2 CFR Part 200, Subpart E. Condition: Costs were booked to incorrect program codes, resulting in unsupported charges being booked to the federal program. Both payroll and non-payroll expenditures were charged to the Federal program prior to the period of performance start date. Questioned costs: Known $1,098 Context: In period of performance testing, the majority of samples tested for beginning period of performance (31/40 samples) related to June 2024 payroll. In all of these tested samples, time was booked to the Federal program prior to the program start date of June 20, 2024. Similarly, there was no adjustments for other charges that are normally booked for the full month at a time, including: per diems (2/40 samples) and fuel (1/40 samples). One additional error was related to time booked to the Federal program when no time was coded to that program during the pay period tested. The final error was related to February amortization that was not processed in time and therefore mistakenly booked to the program. In payroll testing, 2/40 samples tested were booked to a charge code that was not reflected in the supporting timesheets. The amounts booked incorrectly to the major program are considered unallowable costs. Cause: MTI payroll is run monthly. Time should not have been coded to the Federal program in question until the program start date of June 20, 2024, however as most programs begin on the first of the month (not mid-month) this was overlooked by the supervisors and finance team who are supposed to review timesheets and make correction to ensure allocations are booked to the correct programs for the correct dates. Additional errors due to human error. Effect: Costs incurred outside of the Federal program's period of performance and costs that are not supported by underlying documentation are not allowable under the program. The organization may be required to submit reimbursements for these amounts. Repeat Finding: No Recommendation: Management should review its existing control structure and ensure that there are adequate processes and controls to ensure only expenditures incurred during the period of performance are booked to Federal programs and that the correct program codes are charged, based on the underlying supporting documentation. Views of responsible officials: There is no disagreement with the audit finding.

Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.

Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.

Finding: 2022-001 Federal Agency: U.S. Department of the State, Bureau of Population, Refugees, and Migration Program Name: Overseas Refugee Assistance Programs for Africa AL # and Program Name: 19.517 Overseas Refugee Assistance Programs for Africa Federal Award Numbers: N/A Federal Award Year: October 1, 2021 to September 30, 2022 Questioned Costs: Known: None Likely: None Compliance Requirement: Reporting Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred to as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward / subaward amendment obligation was made or the subcontract award / subcontract modification was made. Condition Found For ALN 19.517, two of two subawards selected for testing was obligated during fiscal year 2022 but were not reported per the criteria above. Cause and Effect The control for submission of FFATA reports was not in place during the 2022 fiscal year and the reports weren't submitted. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This finding is not a repeat finding in the immediately prior audit. Recommendation We recommend that management design a control process to properly monitor and manage timely subaward report submissions. Views of Responsible Officials Medical Teams International agrees that the two FFATA reports were not submitted to the FSRS. Medical Teams International intends to implement a control process for collecting required information, train relevant staff, and review reporting status to ensure FFATA reports are submitted to FSRS prior to the reporting due date.

Overseas Refugee Assistance Programs for Africa: Comprehensive Health

Findings and Questioned Costs ? Major Federal Award Program Audit Finding 2019-001 Type of Finding: Material weakness in internal control over compliance and material noncompliance Federal Agency: Department of State, Bureau of Population, Refugees, and Migration Federal Program: CFDA # 19.517 ? Overseas Refugee Assistance Programs for Africa Grant No.: S-PRMCO-18-CA-0070; S-PRMCO-18-CA-0069; S-PRMCO-19-CA-0091; S-PRMCO-19-CA-0012 Known Questioned Costs: $92,513 Likely Questioned Costs: Present and indeterminable Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart E, Section 403 indicates that in order for costs to be allowable under federal awards that they must be adequately documented. Conditions: A) While performing audit procedures over cash disbursements and personnel expenses, we noted that there was inadequate documentation for 7 transactions out of our sample of 80. These cash disbursements and payroll expenses were all from the Organization?s Tanzania location. Management informed us that they would be unable to provide further support for cash disbursements and/or personnel expenses from that location due to a ?tenuous political situation in that region.? Total known questioned costs from these 7 transactions was $48,278. While there are likely to be questioned costs beyond the $48,278 that we identified in performing our audit procedures, we are unable to determine the extent or amount of those additional likely questioned costs. Total federal program expenditures in Tanzania for the year ended September 30, 2019 totaled $2,370,288. We did not utilize statistical sampling. B) During the audit, we were made aware that the Organization conducted an internal investigation which included a review of 90 percent of the disbursements from their Uganda locations for the period of January 1, 2019 ? June 30, 2019. It was determined through the course of that investigation that there was inadequate documentation for numerous transactions. While management notes in their response that they were later able to locate appropriate documentation after their internal investigation was complete, we were not provided with documentation for those disbursements in question during our audit. The disbursements lacking adequate documentation totaled $44,235. Cause: The internal controls in place with the intent to ensure that costs are adequately documented were not operating effectively. The key controls in place that were not operating effectively include the following: 1) Expenses are supported by vendor invoices or other applicable supporting documentation for the amount and the date the expense was incurred. 2) Invoices or other supporting documentation for expenses are authorized by an appropriate employee prior to payment. 3) Employment contracts are signed by the employee and Country Director and approved by the Human Resource and Administration Manager. 4) Timesheets are approved by the employee and at least one supervisor. Effect of condition: The costs that were not adequately documented may be disallowed. Repeat Finding: No Recommendation: A) We recommend that management review the internal controls in place for document retention for their international locations to ensure that the Organization has access to supporting documentation when needed. The Organization could consider utilizing a cloud based accounting system whereby supporting documents are electronically attached to the accounting transactions so that necessary parties have access when needed. B) We recommend that management review the internal controls in place to ensure that all transactions are adequately documented. Views of Responsible Officials: A) Due to the political dynamic within Tanzania, Medical Teams could only implement the grant through the Tanzania Red Cross Society (TRCS), as an implementing partner, as only TRCS has the approval of the Tanzania Ministry of Health. As many other NGOs have experienced, TRCS has been difficult in providing proper support for payments. In this case, because MTI could attest to the work being done, MTI initiated payment to TRCS in order to ensure their payroll was met. Efforts to get supporting documentation have been unsuccessful. MTI has had discussion with the donors and have asked for guidance, however, none was given. Although the environment and the partner have made it challenging to operate in Tanzania for Medical Teams, we remain committed to the mission of Medical Teams, to provide healing and hope to the Burundian and Congolese refugees in Western Tanzania. B) Medical Teams maintains a hotline reporting process that served its purpose in providing a means for concerns to be reported and further investigated. Medical Teams agrees that there were transactions identified by our investigators for which documentation was not immediately presented, however, supporting documentation for many of those transactions were later located. As the investigators weren?t charged with subsequent work to validate all exception transactions, we disagree with the amount of questioned costs resulting from unsupported transactions as that support was able to be verified.