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Internal Controls That Actually Fit a Small Hospice

Jump to the bottom to hear Justin explain this.

If your hospice has one bookkeeper, a part-time CFO (or none at all), and a finance committee that meets four times a year, the standard internal controls playbook doesn’t fit your organization. Large health systems with dedicated compliance departments and multi-layer approval workflows shaped those best practices.

But the risks are the same. The dollar amounts are smaller — but so is your margin for error. A single fraud incident or accounting failure could leave your organization tied up in a mess for weeks and further hurt relationships with key donors. The most common failure points are not exotic. They are the boring, everyday things that never get fixed because everyone assumes someone else is watching.

Here are four controls that are practical for a small hospice, require no new headcount, and protect against the places where things actually go wrong.

The Bank Reconciliation Gap

Bank reconciliation is one of the most fundamental financial controls in any organization. Someone prepares it; another person reviews it. At a large organization, those two roles are easy to separate. At a small hospice, the person who closes the books and the person who signs the checks are often the same person — or close enough that the review is a rubber stamp.

The fix does not require hiring anyone. It requires identifying a second set of eyes who is not involved in day-to-day bookkeeping — a finance committee member, a board treasurer, or an executive director who reviews the reconciliation as a standing monthly task. A reviewer does not need to be a CPA. They need to look at the reconciled balance, confirm it matches the bank statement, and flag anything unusual.

When a staff member who was also the primary bookkeeper left a hospice we work with, the secondary reviewer role sat vacant for months without anyone noticing. Designating a board-level reviewer as a standing position — not tied to a specific staff member — eliminates that gap. As soon as someone leaves, the process does not leave with them.

Shared Credit Cards

Shared credit cards are one of the most common internal control failures in small nonprofits, and almost everyone has them. A card in the organization’s name gets passed around between staff, volunteers, or board members for approved purchases. It is convenient. It is also a significant liability for whoever’s name is on the card and a compliance risk for the organization.

The practical fix is virtual cards. Platforms like Divvy let you issue one-off virtual card numbers with specific spending limits and expiration dates. If you need to send a volunteer to buy supplies for a fundraiser, issue a virtual card for $150 that expires in 48 hours. The card is tied to that person and that purpose — not to a shared physical card that could be used for anything by anyone.

Using virtual cards also solves the reconciliation problem that comes with shared cards.. When a single card is used by multiple people, matching receipts to transactions becomes a manual puzzle every month. With individually issued virtual cards, every transaction is already attributed. The reconciliation writes itself.

Investment Account Access

Many small hospices hold CDs, money market accounts, or investment accounts as part of their cash management strategy. Organizations often set up access to those accounts (the ability to initiate transfers, redeem funds, or change allocations) once and never revisit it. By the time the original signatory leaves or the organization’s leadership changes, nobody is entirely sure who has access to what.

At minimum, your investment accounts should require dual authorization for any transfer or redemption above a defined threshold. That threshold should be set by your finance committee and documented in your investment policy. Make CD renewals and reinvestment decisions a standing finance committee agenda item instead of allowing automatic rollovers without board awareness.

The principle is simple: any account that holds significant organizational assets should require two humans to agree before money moves. If your current setup does not require that, it is worth a conversation with your bank or investment custodian this quarter.

The Treasurer as Bank Signatory

Most small hospices have an executive director as the primary signatory on their operating checking account. That is appropriate. What is often missing is a secondary signatory at the board level — typically the treasurer — who provides an independent check on the account without being involved in day-to-day operations.

You can add your treasurer as a secondary signatory with about one hour at your bank. It does not mean every check requires two signatures (though for large disbursements, it should). It means that if something unusual happens — an unexpected wire, a vendor dispute, an account access question — there is a board-level officer who can step in with authority. More importantly, it also shows your auditors, funders, and staff that your board actively participates in financial oversight, not just advisory work.

If your treasurer has never been to your bank branch, that is worth fixing. It takes less than an hour and closes a gap that has tripped up more than a few small nonprofits when their ED role turns over unexpectedly.

The Underlying Principle

None of these controls require a compliance team, a new software platform you cannot afford, or a board that meets every week. They require one thing: that no single person has unchecked access to money, reconciliation, and reporting at the same time.

Small hospices earn trust from their communities, their funders, and their referral sources in part by demonstrating financial integrity. The controls that protect that integrity do not need to be complex. They need to be consistent, documented, and reviewed at least annually — preferably as part of your audit process.

Want to Know Where Your Gaps Are?

Universal Bookkeeper works exclusively with hospices on financial reporting, controls, and governance. We review financial controls as part of our onboarding process for every new client and flag gaps as a standing part of our annual audit support.

Send us your last audit report or board financial packet. We will show you where your current controls have gaps and what a practical fix looks like for your size and team — no commitment required.

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