U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Procurement, Suspension and Debarment
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal control over federal awards that provides reasonable assurance that the Foundation is
managing the federal award in compliance with federal statutes, regulations and terms and
conditions of the federal award. The non‐Federal entity’s documented procurement procedures
must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which
also requires documentation to be retained to detail the history of procurements. In addition, as
outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or
is otherwise excluded from the central contractor registry.
Condition: The Foundation did not retain documentation to support performance a price
analysis nor provide the opportunity for open competition. Additionally, the Foundation did not
review for suspension or debarment and required contract provisions were not followed.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of procurement.
Effect: Improper expenses may be paid and charged to the federal program and covered
transactions could be potentially entered into with suspended or debarred parties.
Questioned Costs: Questioned costs were unable to be determined.
Context: A nonstatistical sample of 12 transactions out of 60 total transactions were selected for
testing totaling $148,605 of $275,567 procurement expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation follow designed control processes which
includes performing required procurement procedures and maintaining within the procurement
file documentation of a review to ensure the party to the covered transaction is not suspended
or debarred.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal control over federal awards that provides reasonable assurance that the Foundation is
managing the federal award in compliance with federal statutes, regulations and terms and
conditions. A complete system of internal controls requires all expenditures be properly
approved and supported by appropriate documentation. In addition, all expenditures charged to
the federal program are required to be allowable costs under the program and based on actual,
and not budgeted amounts.
Condition: 51 out of 60 expenditures tested lacked proper documentation of review and
approval. 51 out of 60 expenditures tested were based on budgeted amounts expended and not
actual amounts with no true up performed. 1 out of 60 expenditures tested were deemed
unallowable based on the terms of the grant agreement.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of expenditures charged to the program for allowable activities and allowable costs. The
Organization did not have controls in place to properly allocate, record and track actual costs
incurred to the grant.
Effect: Not having a system to track actual grant expenditures incurred properly to grants
increases risk that improper expenses may be paid and charged to the federal program or
charged at the wrong amount.
Questioned Costs: Total known questioned costs are $53,986.
Context: A nonstatistical sample of 60 transactions were selected for testing, which accounted
for $297,033 of $640,075 reported program expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management implement a process that
allows for actual expenditures to tracked, allocated, and be billed to the specific program and
ensure that supporting documentation of review is retained to demonstrate compliance with
the federal program.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Reporting
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal controls over the federal awards that provide assurance that the entity is managing the
federal awards in compliance with federal statutes, regulations, and the conditions of the
federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial
information and monitor its activities under federal awards to assure compliance with applicable
federal requirements, to assure performance expectations are being achieved, and to report
these items in accordance with program requirements. The Foundation is required to submit
quarterly performance reports. Reports should be prepared complete, accurate, and in
accordance with the required basis for reporting, submitted timely with the terms of the grant
award, and reviewed by an individual prior to submission to ensure accuracy.
Condition: Although the reports were reviewed in accordance with internal controls, the review
process did not properly identify on two out of the two reports tested that they were submitted
with inaccurate information. Supporting documentation for the reports submitted used
budgeted expensed amounts, not actual, and the budgeted expensed amounts for the period
did not agree to amounts reported.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of information included in reports to ensure completeness and accuracy.
Effect: Inaccurate information may be provided to the grantor regarding performance of the
Foundation.
Questioned Costs: None reported.
Context: A nonstatistical sample of 2 out of 4 reports submitted were selected for testing.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management routinely review and consider
modifications that would strengthen the internal controls surrounding the reporting process,
recordkeeping, and the management thereof. Specifically, management should ensure that
financial records are such to provide actual amounts of grant expenditures incurred for
reporting purposes at required reporting dates, and that the review control ensures that reports
provided to grantors agree with internal financial records.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Period of Performance
Material Weakness in Internal Control over Compliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal controls over the federal awards that provide assurance that the entity is managing the
federal awards in compliance with federal statutes, regulations, and the conditions of the
federal award. A complete system of internal controls requires all expenditures be properly
approved and supported by appropriate documentation. In addition, all expenditures charged to
the federal program are required to be reviewed to ensure they are within the grant award’s
period of performance.
Condition: The Foundation’s internal controls were not designed to properly ensure an review
over program expenditures and that they were incurred within the grant award’s period of
performance.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of expenditures charged to the program to ensure they were incurred within the period
of performance.
Effect: Lack of a formal review control over period of performance requirements increases the
risk that expenditures could be submitted under the grant that are incurred outside of the
period of performance.
Questioned Costs: None reported.
Context: A nonstatistical sample of 60 transactions were selected for testing, of which 51 out of
60 expenditures tested lacked proper documentation of review and approval with period of
performance requirements.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management implement a process that
allows for expenditures claimed for reimbursement under federal awards to be reviewed to
ensure those expenditures are incurred within the grant award’s period of performance
requirements.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Procurement, Suspension and Debarment
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal control over federal awards that provides reasonable assurance that the Foundation is
managing the federal award in compliance with federal statutes, regulations and terms and
conditions of the federal award. The non‐Federal entity’s documented procurement procedures
must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which
also requires documentation to be retained to detail the history of procurements. In addition, as
outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or
is otherwise excluded from the central contractor registry.
Condition: The Foundation did not retain documentation to support performance a price
analysis nor provide the opportunity for open competition. Additionally, the Foundation did not
review for suspension or debarment and required contract provisions were not followed.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of procurement.
Effect: Improper expenses may be paid and charged to the federal program and covered
transactions could be potentially entered into with suspended or debarred parties.
Questioned Costs: Questioned costs were unable to be determined.
Context: A nonstatistical sample of 12 transactions out of 60 total transactions were selected for
testing totaling $148,605 of $275,567 procurement expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation follow designed control processes which
includes performing required procurement procedures and maintaining within the procurement
file documentation of a review to ensure the party to the covered transaction is not suspended
or debarred.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal control over federal awards that provides reasonable assurance that the Foundation is
managing the federal award in compliance with federal statutes, regulations and terms and
conditions. A complete system of internal controls requires all expenditures be properly
approved and supported by appropriate documentation. In addition, all expenditures charged to
the federal program are required to be allowable costs under the program and based on actual,
and not budgeted amounts.
Condition: 51 out of 60 expenditures tested lacked proper documentation of review and
approval. 51 out of 60 expenditures tested were based on budgeted amounts expended and not
actual amounts with no true up performed. 1 out of 60 expenditures tested were deemed
unallowable based on the terms of the grant agreement.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of expenditures charged to the program for allowable activities and allowable costs. The
Organization did not have controls in place to properly allocate, record and track actual costs
incurred to the grant.
Effect: Not having a system to track actual grant expenditures incurred properly to grants
increases risk that improper expenses may be paid and charged to the federal program or
charged at the wrong amount.
Questioned Costs: Total known questioned costs are $53,986.
Context: A nonstatistical sample of 60 transactions were selected for testing, which accounted
for $297,033 of $640,075 reported program expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management implement a process that
allows for actual expenditures to tracked, allocated, and be billed to the specific program and
ensure that supporting documentation of review is retained to demonstrate compliance with
the federal program.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Reporting
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal controls over the federal awards that provide assurance that the entity is managing the
federal awards in compliance with federal statutes, regulations, and the conditions of the
federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial
information and monitor its activities under federal awards to assure compliance with applicable
federal requirements, to assure performance expectations are being achieved, and to report
these items in accordance with program requirements. The Foundation is required to submit
quarterly performance reports. Reports should be prepared complete, accurate, and in
accordance with the required basis for reporting, submitted timely with the terms of the grant
award, and reviewed by an individual prior to submission to ensure accuracy.
Condition: Although the reports were reviewed in accordance with internal controls, the review
process did not properly identify on two out of the two reports tested that they were submitted
with inaccurate information. Supporting documentation for the reports submitted used
budgeted expensed amounts, not actual, and the budgeted expensed amounts for the period
did not agree to amounts reported.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of information included in reports to ensure completeness and accuracy.
Effect: Inaccurate information may be provided to the grantor regarding performance of the
Foundation.
Questioned Costs: None reported.
Context: A nonstatistical sample of 2 out of 4 reports submitted were selected for testing.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management routinely review and consider
modifications that would strengthen the internal controls surrounding the reporting process,
recordkeeping, and the management thereof. Specifically, management should ensure that
financial records are such to provide actual amounts of grant expenditures incurred for
reporting purposes at required reporting dates, and that the review control ensures that reports
provided to grantors agree with internal financial records.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa
County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State
and Local Fiscal Recovery Funds
Period of Performance
Material Weakness in Internal Control over Compliance
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective
internal controls over the federal awards that provide assurance that the entity is managing the
federal awards in compliance with federal statutes, regulations, and the conditions of the
federal award. A complete system of internal controls requires all expenditures be properly
approved and supported by appropriate documentation. In addition, all expenditures charged to
the federal program are required to be reviewed to ensure they are within the grant award’s
period of performance.
Condition: The Foundation’s internal controls were not designed to properly ensure an review
over program expenditures and that they were incurred within the grant award’s period of
performance.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of expenditures charged to the program to ensure they were incurred within the period
of performance.
Effect: Lack of a formal review control over period of performance requirements increases the
risk that expenditures could be submitted under the grant that are incurred outside of the
period of performance.
Questioned Costs: None reported.
Context: A nonstatistical sample of 60 transactions were selected for testing, of which 51 out of
60 expenditures tested lacked proper documentation of review and approval with period of
performance requirements.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Foundation’s management implement a process that
allows for expenditures claimed for reimbursement under federal awards to be reviewed to
ensure those expenditures are incurred within the grant award’s period of performance
requirements.
Views of Responsible Officials: Management agrees with the finding.