Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR section 576.203(a)(2) states ? Within 180 days after the date that HUD signs the grant agreement (or a grant amendment for reallocation of funds) with the metropolitan city, urban county, or territory, the recipient must obligate all the grant amount, except the amount for its administrative costs. This requirement is met by an agreement with, or a letter of award requiring payment to, a subrecipient; a procurement contract; or a written designation of a department within the government of the recipient to directly carry out an eligible activity. Condition: The City?s Department of Housing Stability (HOST) did not have controls in place to ensure funds were obligated within the required obligation period. In addition, the City did not timely obligate funds within 180 days of the signing of the 2021 fiscal year grant agreement by HUD. Cause: HOST did not have internal controls in place to ensure funds were obligated within the required time period. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(a)(2) regarding obligation of funds. Questioned Costs: None Context: BDO tested the entire population of six subrecipient contracts related to award E-21-MC-08-0005 totaling to $448,444. BDO found that two of the six contracts were obligated outside of the required time period. The amount of funds obligated after the 180 days was $144,122. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-010 in the 2021 report. Recommendation: HOST should create a tracking tool to ensure program year funds are tracked and obligated within required time periods. This should be supplemented with written policies and procedures pertaining to timely obligation of Emergency Solutions Grant (ESG) funds. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR 576.203(c) states ? The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Condition: HOST did not have adequate controls in place to ensure subrecipients were timely paid after receiving complete payment requests. HOST did not make payments to its subrecipients within 30 days after receiving complete payment requests. Cause: HOST did not have adequate internal controls in place to ensure payments were made timely to subrecipients. Five of the exceptions were due to budget modifications, which resulted in payment delays. Three of the payments were sent to the Controller?s Office prior to the 30-day requirement. However, the payments were still made past the deadline. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(c) regarding payments to subrecipients. Questioned Costs: None Context: BDO selected a sample of 60 payments to subrecipients totaling to $2,091,379 from a population of 433 payments totaling to $7,710,136. There were eight payments totaling to $459,439 in which the invoice was not paid within 30 days of when a complete payment request was submitted to the City. This is a condition identified per review of the City?s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: N/A Recommendation: HOST should implement controls to ensure subrecipients who submit complete invoices for payment are paid within 30 days. Steps should be taken to reduce the frequency and time associated with budget modifications to ensure payments are made timely. Finally, communication should take place between HOST and the Controller?s Office to expedite payments to subrecipients and prevent unnecessary delays. Views of Responsible Officials: The City agrees with the finding and internal policies have been updated to require finance budget review prior to contract execution to avoid budget modifications during the payment process. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: HOST?s form used to track matching provided by subrecipients did not have evidence to indicate (1) numbers per the match reports were reconciled to supporting documentation provided by the subrecipient and (2) sign off to evidence review. The form also did not have a record of the fiscal year ESG grant for which the matching contribution was being made. Cause: Controls were not sufficiently designed to ensure information provided by the subrecipients was correct, and that matching requirements were met. Effect or Potential Effect: Inadequate controls over review of the match reports could result in matching requirements not being fulfilled by subrecipients in accordance with 24 CFR 576.201. Questioned Costs: None Context: A sample of four match reports was selected from a population of six. For each match report selected, there was no evidence of review of the match form for accuracy. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: The current matching form should be improved to identify the Federal ESG fiscal year award. The form should also include evidence it was reviewed and approved by a designated individual within HOST. Views of Responsible Officials: The City disagrees with the finding. The City has created an ESG match guide and reporting template and has provided training for subrecipients utilizing ESG funds. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The City department of HOST did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment. During our testing of procurement and suspension and debarment, we noted two of the three procurements sampled did not have evidence to support operation of the control verifying whether a subrecipient/vendor was listed as a suspended or debarred entity on SAM.gov. HOST did have a compensating control in place pertaining to review of contracts to ensure suspension and debarment certifications were present. Cause: The department?s review control was not operating effectively to ensure suspension and debarment searches were being performed. No documentation was retained to support such review took place. Effect or Potential Effect: The Department could have potentially entered into contracts with subrecipients or vendors who were included on the suspension and debarment listing at SAM.gov. In completion of our compliance testing, BDO noted that none of the subrecipients or vendors tested were on the excluded parties list. Questioned Costs: None Context: We tested a sample of three transactions totaling to $922,490 from a population of 13 transactions totaling to $7,710,136. The results of testing found two instances in which HOST did not document their search of SAM.gov to ensure the subrecipient or vendor was not suspended or debarred prior to awarding the contract. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-011 in the 2021 report. Recommendation: HOST should follow their documented internal control procedures to ensure the SAM.gov search is performed and documentation is retained to support compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure this has been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR 576.203(c) states ? The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Condition: HOST did not have adequate controls in place to ensure subrecipients were timely paid after receiving complete payment requests. HOST did not make payments to its subrecipients within 30 days after receiving complete payment requests. Cause: HOST did not have adequate internal controls in place to ensure payments were made timely to subrecipients. Five of the exceptions were due to budget modifications, which resulted in payment delays. Three of the payments were sent to the Controller?s Office prior to the 30-day requirement. However, the payments were still made past the deadline. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(c) regarding payments to subrecipients. Questioned Costs: None Context: BDO selected a sample of 60 payments to subrecipients totaling to $2,091,379 from a population of 433 payments totaling to $7,710,136. There were eight payments totaling to $459,439 in which the invoice was not paid within 30 days of when a complete payment request was submitted to the City. This is a condition identified per review of the City?s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: N/A Recommendation: HOST should implement controls to ensure subrecipients who submit complete invoices for payment are paid within 30 days. Steps should be taken to reduce the frequency and time associated with budget modifications to ensure payments are made timely. Finally, communication should take place between HOST and the Controller?s Office to expedite payments to subrecipients and prevent unnecessary delays. Views of Responsible Officials: The City agrees with the finding and internal policies have been updated to require finance budget review prior to contract execution to avoid budget modifications during the payment process. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The City department of HOST did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment. During our testing of procurement and suspension and debarment, we noted two of the three procurements sampled did not have evidence to support operation of the control verifying whether a subrecipient/vendor was listed as a suspended or debarred entity on SAM.gov. HOST did have a compensating control in place pertaining to review of contracts to ensure suspension and debarment certifications were present. Cause: The department?s review control was not operating effectively to ensure suspension and debarment searches were being performed. No documentation was retained to support such review took place. Effect or Potential Effect: The Department could have potentially entered into contracts with subrecipients or vendors who were included on the suspension and debarment listing at SAM.gov. In completion of our compliance testing, BDO noted that none of the subrecipients or vendors tested were on the excluded parties list. Questioned Costs: None Context: We tested a sample of three transactions totaling to $922,490 from a population of 13 transactions totaling to $7,710,136. The results of testing found two instances in which HOST did not document their search of SAM.gov to ensure the subrecipient or vendor was not suspended or debarred prior to awarding the contract. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-011 in the 2021 report. Recommendation: HOST should follow their documented internal control procedures to ensure the SAM.gov search is performed and documentation is retained to support compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure this has been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 24 CFR Section 92.502(a) states that the participating jurisdiction must report all program income in HUD?s computerized disbursement and information system. 24 CFR Section 92.508(a) states each participating jurisdiction must establish and maintain sufficient records to enable HUD to determine whether the jurisdiction has met the requirements of this part. At a minimum, the following records are needed: (5)(iii) Records identifying the source and application of program income, repayments and recaptured funds; (5)(iv) Records demonstrating adequate budget control and other records required by 2 CFR 200.302, including evidence of periodic account reconciliations. Condition: Program income per the financial reporting system of the City and receipted within HUD?s Integrated Disbursement and Information System (IDIS), did not match actual program income earned by the program for the year ended December 31, 2022. Testing of the annual reconciliation of program income revealed program income was overstated by $48,500 within IDIS. Cause: Policies and procedures were not sufficiently designed to ensure accurate review of program income transactions. Reconciliations performed did not catch this difference, which also contributed to the condition. Effect or Potential Effect: Program income was incorrectly receipted within IDIS in the amount of $48,500. Questioned Costs: None Context: BDO tested the annual reconciliation of program income. Total program income reported per the general ledger and within IDIS was $1,165,923. Program income reported per the reconciliation of program income was $1,117,423. The error of $48,500 pertained to program income for ALN 14.256 being improperly credited to program income for ALN 14.239 in the general ledger. Identification as a Repeat Finding: N/A Recommendation: Controls over review of program income transactions should be improved to ensure transactions are adequately reviewed prior to posting within the general ledger. In addition, compensating controls such as the reconciliation of program income per the City?s loan portfolio software and the general ledger should be strengthened to act as a secondary catch to ensure correct amounts of program income are reported and receipted into IDIS. Views of Responsible Officials: The City agrees with the finding and will implement a reconciliation process of reconciling each fund with each revenue category quarterly. For additional information, please see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: There was no evidence available to document that someone was reviewing Federal Funding and Accountability Transparency Act (FFATA) reports prior to submission. During our testing of such reports, three exceptions were noted in which there was no evidence of review of the report prior to submission. Cause: Policies and procedures were not sufficiently designed to ensure reviews of FFATA reports submitted were documented. Effect or Potential Effect: If there is not a formalized and documented review process, incorrect information could be submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Context: All three FFATA reports required for 2022 were tested. None of the three submitted reports had evidence to support review prior to submission. Identification as a Repeat Finding: N/A Recommendation: HOST should implement procedures to ensure submissions of FFATA reports are reviewed. This should be documented via e-mail or initials on the reports submitted. Another suggestion could be a checklist filled out evidencing what was reviewed and by whom. Views of Responsible Officials: The City agrees with the finding and will implement procedures to effectively review its FFATA reports submitted through FSRS. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: There was no evidence available to document that someone was reviewing Federal Funding and Accountability Transparency Act (FFATA) reports prior to submission. During our testing of such reports, three exceptions were noted in which there was no evidence of review of the report prior to submission. Cause: Policies and procedures were not sufficiently designed to ensure reviews of FFATA reports submitted were documented. Effect or Potential Effect: If there is not a formalized and documented review process, incorrect information could be submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Context: All three FFATA reports required for 2022 were tested. None of the three submitted reports had evidence to support review prior to submission. Identification as a Repeat Finding: N/A Recommendation: HOST should implement procedures to ensure submissions of FFATA reports are reviewed. This should be documented via e-mail or initials on the reports submitted. Another suggestion could be a checklist filled out evidencing what was reviewed and by whom. Views of Responsible Officials: The City agrees with the finding and will implement procedures to effectively review its FFATA reports submitted through FSRS. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. ERA Reporting Guidance v 3.4 identifies monthly reports and quarterly reports required to be submitted for the Emergency Rental Assistance Program (ERAP). Key line items for these reports are outlined within the Compliance Supplement and include for monthly reports- (1) total number of participating households that received ERAP assistance of any kind; (2) total amount of ERAP funds expended by the ERAP grantee to or for participating households and for quarterly reports- (1) the cumulative amount obligated by the grantee and (2) the cumulative amount expended by the grantee. ERA Reporting Guidance v 3.4 defines an obligation as ??a commitment to pay a third party with ERA award proceeds based on a contract, subaward, direct payment, or other arrangement.? U.S Department of the Treasury Emergency Rental Assistance Under the Consolidated Appropriations Act, 2021 Reallocation Guidance (Reallocation Guidance), issued October 4, 2021, and updated September 6, 2022, states ?Grantees are encouraged to partner with local nonprofit organizations and governmental agencies to expedite the obligation process and delivery of assistance to eligible households. However, grantees may not use subrecipient agreements with these entities to avoid meeting the statutory obligation deadline, and funds will not be considered obligated based solely on the fact they are subject to an agreement that provides for another entity to administer assistance on the grantee?s behalf.? The Reallocation Guidance further states Treasury will conduct a final assessment of each grantee?s Expenditure Ratio based on data reported through March 31, 2022. At that time, any unobligated ERA1 funds may be determined to be excess funds. Condition: During our testing of reporting, we noted for three of the eight reports, discrepancies between amounts included in the reports and relevant supporting documentation. Cause: The Department?s supervisory and review control was not operating effectively to ensure that all key line items reported in the monthly and quarterly reports were properly supported. Effect or Potential Effect: Incorrect information, especially pertaining to the reporting of obligations, was reported to Treasury, which could have affected decisions pertaining to unobligated funds existing as of March 31, 2022. Questioned Costs: None Context: We tested a sample of eight reports from a population of 20. We identified exceptions in three of the reports tested. The exceptions by report are as follows: **ERA2 Quarter 3 Report- Current quarter obligations in the amount of $4,492,359, which were key in determining cumulative obligations to date, were traced to supporting documentation. However, such amounts were different by $58,019. **ERA1 Quarter 1 Report- (1) The cumulative amount of award obligated as of the end of the reporting period was stated at the full amount of the grant award ($21,884,992). This appeared to be overstated based on the Reallocation Guidance from Treasury. The exact amount of what cumulative obligations should have been was not determinable. HOST corrected the practice on future quarterly reports. **March 2022 ERA1 Monthly Report- Data did not trace back to supporting schedules. Total rental payments to individuals were reported as $1,565,364 with 275 households. Supporting schedules showed $1,562,973 with 274 households. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: Documentation should be kept for all numbers on reports submitted and review of reports submitted should contain evidence that someone reviewed and traced key report line items to supporting documentation. Such evidence should be filed with each report (i.e., signed checklist of what was done prior to reports being submitted or e-mail approval). Views of Responsible Officials: The City agrees with the finding. HOST will establish a reporting checklist and an e-mail approval with evidence of the review of documentation supporting the numbers being submitted in reports. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: During our testing of payroll disbursements, we noted one of the six disbursements tested did not have evidence of supervisor approvals. Cause: HOST?s policies and procedures for manually reviewing and approving payroll disbursements outside of the Kronos timekeeping system were not appropriately adhered to. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: BDO tested a sample of six timecards totaling to $20,008 from a population of 23 timecards totaling to $92,643 and found one exception noted in the condition. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: HOST should ensure that all timecards for individuals charging time and effort to the program be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. The finding was for a transaction during a time the Kronos system was down. The City has now transitioned to tracking time and effort in Workday that requires supervisor review and approval. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 200.332 states- All pass-through entities must ensure that every subaward is clearly identified to the subrecipient and includes the following information at the time of the subaward as follows: (1) Federal award identification, (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports, (4) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (5) Appropriate terms and conditions concerning the closeout of the subaward. Condition: We noted that, for all five subrecipients tested, subaward agreements did not include the award information required under 2 CFR 200.332. Cause: Subaward agreements were not properly written and appropriately reviewed to ensure all required award information was included. Effect or Potential Effect: Denver Department of Public Health and Environment (DDPHE) was not in compliance with subrecipient requirements outlined in 2 CFR Section 200.332. Furthermore, not communicating proper compliance requirements and other information may increase the likelihood of noncompliance on the part of the subrecipient and non-fulfillment of program goals and objectives. In addition, this also increases the risk the subrecipient may not understand they are receiving Federal funds, which could result in subrecipients failing to comply with the Uniform Guidance or pass-through entity requirements for the award. Questioned Costs: None Context: BDO selected five subawards totaling to $875,589 to test from a population of 11 subawards totaling to $1,084,199. BDO noted that all five subawards tested did not include the required Federal award identification or applicability of audit requirements. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DDPHE should revise subaward agreements to include specific Federal award identification information and language clearly stating applicable audit requirements subrecipients must comply with to ensure all agreements are in compliance with the requirements in 2 CFR Section 200.332. Views of Responsible Officials: The City agrees with the finding and DDPHE will consult with the City?s Federal Grants Manager and other parties to review the current standard contract provisions and will modify those provisions accordingly. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (the following is not a comprehensive list of requirements): ** Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. ** Be incorporated into the official records of the non-Federal entity. ** Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. ** Encompass both federally assisted, and all other activities compensated by the non- Federal entity on an integrated basis but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. ** Comply with the established accounting policies and practices of the non-Federal entity. ** Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: The City did not have records to adequately support payroll costs of the DDPHE Department Director allocated to the program. Cause: The City does not require employees working on multiple programs to certify their time and effort spent on each program. Time charged for the Director was based on a flat rate percentage of 25%; there was no support for the percentage used. Effect or Potential Effect: Payroll expenditures charged to the grant may be in excess of actual time and effort devoted to the program. Questioned Costs: The total amount of payroll charged to the program for the DDPHE Department Director of $26,816 (25% of the Director?s annual salary). Context: During follow-up on a prior year finding (2021-015), BDO noted the City had not yet implemented corrective action with respect to how time and effort should be recorded and had not performed periodic reviews to true-up time to the actual time and effort spent on the grant. For the year ended December 31, 2022, a portion of the Director?s salary in the amount of $26,816 was charged to the grant without documentation of time and effort. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-015 in the 2021 report. Recommendation: The Department should implement policies and procedures pertaining to employees not 100% funded by grant programs. These policies and procedures should outline how time and effort should be recorded and provide for periodic reviews to true-up time to the actual time and effort spent on the grant. Views of Responsible Officials: The City agrees with the finding and has implemented a process requiring review and approval of personnel costs that are allocated to the grant at less than 100%. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR section 576.203(a)(2) states ? Within 180 days after the date that HUD signs the grant agreement (or a grant amendment for reallocation of funds) with the metropolitan city, urban county, or territory, the recipient must obligate all the grant amount, except the amount for its administrative costs. This requirement is met by an agreement with, or a letter of award requiring payment to, a subrecipient; a procurement contract; or a written designation of a department within the government of the recipient to directly carry out an eligible activity. Condition: The City?s Department of Housing Stability (HOST) did not have controls in place to ensure funds were obligated within the required obligation period. In addition, the City did not timely obligate funds within 180 days of the signing of the 2021 fiscal year grant agreement by HUD. Cause: HOST did not have internal controls in place to ensure funds were obligated within the required time period. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(a)(2) regarding obligation of funds. Questioned Costs: None Context: BDO tested the entire population of six subrecipient contracts related to award E-21-MC-08-0005 totaling to $448,444. BDO found that two of the six contracts were obligated outside of the required time period. The amount of funds obligated after the 180 days was $144,122. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-010 in the 2021 report. Recommendation: HOST should create a tracking tool to ensure program year funds are tracked and obligated within required time periods. This should be supplemented with written policies and procedures pertaining to timely obligation of Emergency Solutions Grant (ESG) funds. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR 576.203(c) states ? The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Condition: HOST did not have adequate controls in place to ensure subrecipients were timely paid after receiving complete payment requests. HOST did not make payments to its subrecipients within 30 days after receiving complete payment requests. Cause: HOST did not have adequate internal controls in place to ensure payments were made timely to subrecipients. Five of the exceptions were due to budget modifications, which resulted in payment delays. Three of the payments were sent to the Controller?s Office prior to the 30-day requirement. However, the payments were still made past the deadline. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(c) regarding payments to subrecipients. Questioned Costs: None Context: BDO selected a sample of 60 payments to subrecipients totaling to $2,091,379 from a population of 433 payments totaling to $7,710,136. There were eight payments totaling to $459,439 in which the invoice was not paid within 30 days of when a complete payment request was submitted to the City. This is a condition identified per review of the City?s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: N/A Recommendation: HOST should implement controls to ensure subrecipients who submit complete invoices for payment are paid within 30 days. Steps should be taken to reduce the frequency and time associated with budget modifications to ensure payments are made timely. Finally, communication should take place between HOST and the Controller?s Office to expedite payments to subrecipients and prevent unnecessary delays. Views of Responsible Officials: The City agrees with the finding and internal policies have been updated to require finance budget review prior to contract execution to avoid budget modifications during the payment process. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: HOST?s form used to track matching provided by subrecipients did not have evidence to indicate (1) numbers per the match reports were reconciled to supporting documentation provided by the subrecipient and (2) sign off to evidence review. The form also did not have a record of the fiscal year ESG grant for which the matching contribution was being made. Cause: Controls were not sufficiently designed to ensure information provided by the subrecipients was correct, and that matching requirements were met. Effect or Potential Effect: Inadequate controls over review of the match reports could result in matching requirements not being fulfilled by subrecipients in accordance with 24 CFR 576.201. Questioned Costs: None Context: A sample of four match reports was selected from a population of six. For each match report selected, there was no evidence of review of the match form for accuracy. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: The current matching form should be improved to identify the Federal ESG fiscal year award. The form should also include evidence it was reviewed and approved by a designated individual within HOST. Views of Responsible Officials: The City disagrees with the finding. The City has created an ESG match guide and reporting template and has provided training for subrecipients utilizing ESG funds. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The City department of HOST did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment. During our testing of procurement and suspension and debarment, we noted two of the three procurements sampled did not have evidence to support operation of the control verifying whether a subrecipient/vendor was listed as a suspended or debarred entity on SAM.gov. HOST did have a compensating control in place pertaining to review of contracts to ensure suspension and debarment certifications were present. Cause: The department?s review control was not operating effectively to ensure suspension and debarment searches were being performed. No documentation was retained to support such review took place. Effect or Potential Effect: The Department could have potentially entered into contracts with subrecipients or vendors who were included on the suspension and debarment listing at SAM.gov. In completion of our compliance testing, BDO noted that none of the subrecipients or vendors tested were on the excluded parties list. Questioned Costs: None Context: We tested a sample of three transactions totaling to $922,490 from a population of 13 transactions totaling to $7,710,136. The results of testing found two instances in which HOST did not document their search of SAM.gov to ensure the subrecipient or vendor was not suspended or debarred prior to awarding the contract. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-011 in the 2021 report. Recommendation: HOST should follow their documented internal control procedures to ensure the SAM.gov search is performed and documentation is retained to support compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure this has been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR 576.203(c) states ? The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Condition: HOST did not have adequate controls in place to ensure subrecipients were timely paid after receiving complete payment requests. HOST did not make payments to its subrecipients within 30 days after receiving complete payment requests. Cause: HOST did not have adequate internal controls in place to ensure payments were made timely to subrecipients. Five of the exceptions were due to budget modifications, which resulted in payment delays. Three of the payments were sent to the Controller?s Office prior to the 30-day requirement. However, the payments were still made past the deadline. Effect or Potential Effect: HOST is out of compliance with 24 CFR 576.203(c) regarding payments to subrecipients. Questioned Costs: None Context: BDO selected a sample of 60 payments to subrecipients totaling to $2,091,379 from a population of 433 payments totaling to $7,710,136. There were eight payments totaling to $459,439 in which the invoice was not paid within 30 days of when a complete payment request was submitted to the City. This is a condition identified per review of the City?s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: N/A Recommendation: HOST should implement controls to ensure subrecipients who submit complete invoices for payment are paid within 30 days. Steps should be taken to reduce the frequency and time associated with budget modifications to ensure payments are made timely. Finally, communication should take place between HOST and the Controller?s Office to expedite payments to subrecipients and prevent unnecessary delays. Views of Responsible Officials: The City agrees with the finding and internal policies have been updated to require finance budget review prior to contract execution to avoid budget modifications during the payment process. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The City department of HOST did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment. During our testing of procurement and suspension and debarment, we noted two of the three procurements sampled did not have evidence to support operation of the control verifying whether a subrecipient/vendor was listed as a suspended or debarred entity on SAM.gov. HOST did have a compensating control in place pertaining to review of contracts to ensure suspension and debarment certifications were present. Cause: The department?s review control was not operating effectively to ensure suspension and debarment searches were being performed. No documentation was retained to support such review took place. Effect or Potential Effect: The Department could have potentially entered into contracts with subrecipients or vendors who were included on the suspension and debarment listing at SAM.gov. In completion of our compliance testing, BDO noted that none of the subrecipients or vendors tested were on the excluded parties list. Questioned Costs: None Context: We tested a sample of three transactions totaling to $922,490 from a population of 13 transactions totaling to $7,710,136. The results of testing found two instances in which HOST did not document their search of SAM.gov to ensure the subrecipient or vendor was not suspended or debarred prior to awarding the contract. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2021-011 in the 2021 report. Recommendation: HOST should follow their documented internal control procedures to ensure the SAM.gov search is performed and documentation is retained to support compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure this has been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding. This has been remediated going forward. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 24 CFR Section 92.502(a) states that the participating jurisdiction must report all program income in HUD?s computerized disbursement and information system. 24 CFR Section 92.508(a) states each participating jurisdiction must establish and maintain sufficient records to enable HUD to determine whether the jurisdiction has met the requirements of this part. At a minimum, the following records are needed: (5)(iii) Records identifying the source and application of program income, repayments and recaptured funds; (5)(iv) Records demonstrating adequate budget control and other records required by 2 CFR 200.302, including evidence of periodic account reconciliations. Condition: Program income per the financial reporting system of the City and receipted within HUD?s Integrated Disbursement and Information System (IDIS), did not match actual program income earned by the program for the year ended December 31, 2022. Testing of the annual reconciliation of program income revealed program income was overstated by $48,500 within IDIS. Cause: Policies and procedures were not sufficiently designed to ensure accurate review of program income transactions. Reconciliations performed did not catch this difference, which also contributed to the condition. Effect or Potential Effect: Program income was incorrectly receipted within IDIS in the amount of $48,500. Questioned Costs: None Context: BDO tested the annual reconciliation of program income. Total program income reported per the general ledger and within IDIS was $1,165,923. Program income reported per the reconciliation of program income was $1,117,423. The error of $48,500 pertained to program income for ALN 14.256 being improperly credited to program income for ALN 14.239 in the general ledger. Identification as a Repeat Finding: N/A Recommendation: Controls over review of program income transactions should be improved to ensure transactions are adequately reviewed prior to posting within the general ledger. In addition, compensating controls such as the reconciliation of program income per the City?s loan portfolio software and the general ledger should be strengthened to act as a secondary catch to ensure correct amounts of program income are reported and receipted into IDIS. Views of Responsible Officials: The City agrees with the finding and will implement a reconciliation process of reconciling each fund with each revenue category quarterly. For additional information, please see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: There was no evidence available to document that someone was reviewing Federal Funding and Accountability Transparency Act (FFATA) reports prior to submission. During our testing of such reports, three exceptions were noted in which there was no evidence of review of the report prior to submission. Cause: Policies and procedures were not sufficiently designed to ensure reviews of FFATA reports submitted were documented. Effect or Potential Effect: If there is not a formalized and documented review process, incorrect information could be submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Context: All three FFATA reports required for 2022 were tested. None of the three submitted reports had evidence to support review prior to submission. Identification as a Repeat Finding: N/A Recommendation: HOST should implement procedures to ensure submissions of FFATA reports are reviewed. This should be documented via e-mail or initials on the reports submitted. Another suggestion could be a checklist filled out evidencing what was reviewed and by whom. Views of Responsible Officials: The City agrees with the finding and will implement procedures to effectively review its FFATA reports submitted through FSRS. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: There was no evidence available to document that someone was reviewing Federal Funding and Accountability Transparency Act (FFATA) reports prior to submission. During our testing of such reports, three exceptions were noted in which there was no evidence of review of the report prior to submission. Cause: Policies and procedures were not sufficiently designed to ensure reviews of FFATA reports submitted were documented. Effect or Potential Effect: If there is not a formalized and documented review process, incorrect information could be submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Context: All three FFATA reports required for 2022 were tested. None of the three submitted reports had evidence to support review prior to submission. Identification as a Repeat Finding: N/A Recommendation: HOST should implement procedures to ensure submissions of FFATA reports are reviewed. This should be documented via e-mail or initials on the reports submitted. Another suggestion could be a checklist filled out evidencing what was reviewed and by whom. Views of Responsible Officials: The City agrees with the finding and will implement procedures to effectively review its FFATA reports submitted through FSRS. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. ERA Reporting Guidance v 3.4 identifies monthly reports and quarterly reports required to be submitted for the Emergency Rental Assistance Program (ERAP). Key line items for these reports are outlined within the Compliance Supplement and include for monthly reports- (1) total number of participating households that received ERAP assistance of any kind; (2) total amount of ERAP funds expended by the ERAP grantee to or for participating households and for quarterly reports- (1) the cumulative amount obligated by the grantee and (2) the cumulative amount expended by the grantee. ERA Reporting Guidance v 3.4 defines an obligation as ??a commitment to pay a third party with ERA award proceeds based on a contract, subaward, direct payment, or other arrangement.? U.S Department of the Treasury Emergency Rental Assistance Under the Consolidated Appropriations Act, 2021 Reallocation Guidance (Reallocation Guidance), issued October 4, 2021, and updated September 6, 2022, states ?Grantees are encouraged to partner with local nonprofit organizations and governmental agencies to expedite the obligation process and delivery of assistance to eligible households. However, grantees may not use subrecipient agreements with these entities to avoid meeting the statutory obligation deadline, and funds will not be considered obligated based solely on the fact they are subject to an agreement that provides for another entity to administer assistance on the grantee?s behalf.? The Reallocation Guidance further states Treasury will conduct a final assessment of each grantee?s Expenditure Ratio based on data reported through March 31, 2022. At that time, any unobligated ERA1 funds may be determined to be excess funds. Condition: During our testing of reporting, we noted for three of the eight reports, discrepancies between amounts included in the reports and relevant supporting documentation. Cause: The Department?s supervisory and review control was not operating effectively to ensure that all key line items reported in the monthly and quarterly reports were properly supported. Effect or Potential Effect: Incorrect information, especially pertaining to the reporting of obligations, was reported to Treasury, which could have affected decisions pertaining to unobligated funds existing as of March 31, 2022. Questioned Costs: None Context: We tested a sample of eight reports from a population of 20. We identified exceptions in three of the reports tested. The exceptions by report are as follows: **ERA2 Quarter 3 Report- Current quarter obligations in the amount of $4,492,359, which were key in determining cumulative obligations to date, were traced to supporting documentation. However, such amounts were different by $58,019. **ERA1 Quarter 1 Report- (1) The cumulative amount of award obligated as of the end of the reporting period was stated at the full amount of the grant award ($21,884,992). This appeared to be overstated based on the Reallocation Guidance from Treasury. The exact amount of what cumulative obligations should have been was not determinable. HOST corrected the practice on future quarterly reports. **March 2022 ERA1 Monthly Report- Data did not trace back to supporting schedules. Total rental payments to individuals were reported as $1,565,364 with 275 households. Supporting schedules showed $1,562,973 with 274 households. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: Documentation should be kept for all numbers on reports submitted and review of reports submitted should contain evidence that someone reviewed and traced key report line items to supporting documentation. Such evidence should be filed with each report (i.e., signed checklist of what was done prior to reports being submitted or e-mail approval). Views of Responsible Officials: The City agrees with the finding. HOST will establish a reporting checklist and an e-mail approval with evidence of the review of documentation supporting the numbers being submitted in reports. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: During our testing of payroll disbursements, we noted one of the six disbursements tested did not have evidence of supervisor approvals. Cause: HOST?s policies and procedures for manually reviewing and approving payroll disbursements outside of the Kronos timekeeping system were not appropriately adhered to. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: BDO tested a sample of six timecards totaling to $20,008 from a population of 23 timecards totaling to $92,643 and found one exception noted in the condition. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: HOST should ensure that all timecards for individuals charging time and effort to the program be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. The finding was for a transaction during a time the Kronos system was down. The City has now transitioned to tracking time and effort in Workday that requires supervisor review and approval. For more information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 200.332 states- All pass-through entities must ensure that every subaward is clearly identified to the subrecipient and includes the following information at the time of the subaward as follows: (1) Federal award identification, (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports, (4) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (5) Appropriate terms and conditions concerning the closeout of the subaward. Condition: We noted that, for all five subrecipients tested, subaward agreements did not include the award information required under 2 CFR 200.332. Cause: Subaward agreements were not properly written and appropriately reviewed to ensure all required award information was included. Effect or Potential Effect: Denver Department of Public Health and Environment (DDPHE) was not in compliance with subrecipient requirements outlined in 2 CFR Section 200.332. Furthermore, not communicating proper compliance requirements and other information may increase the likelihood of noncompliance on the part of the subrecipient and non-fulfillment of program goals and objectives. In addition, this also increases the risk the subrecipient may not understand they are receiving Federal funds, which could result in subrecipients failing to comply with the Uniform Guidance or pass-through entity requirements for the award. Questioned Costs: None Context: BDO selected five subawards totaling to $875,589 to test from a population of 11 subawards totaling to $1,084,199. BDO noted that all five subawards tested did not include the required Federal award identification or applicability of audit requirements. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DDPHE should revise subaward agreements to include specific Federal award identification information and language clearly stating applicable audit requirements subrecipients must comply with to ensure all agreements are in compliance with the requirements in 2 CFR Section 200.332. Views of Responsible Officials: The City agrees with the finding and DDPHE will consult with the City?s Federal Grants Manager and other parties to review the current standard contract provisions and will modify those provisions accordingly. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with a person at a lower tier, the non-Federal entity must verify that the person, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The City departments of DDPHE, and several departments (Library, Technology Services, DOTI, Human Rights and Community Partnerships, Arts and Venues, DDPHE, and HOST) administering the CSLFRF program did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment, which included no evidence of a search of the vendor/subrecipient on SAM.gov and insufficient review of contracts to ensure inclusion of suspension and debarment language. Policies and procedures were found to not be followed with respect to suspension and debarment. For ALN 93.391, all five of the procurements sampled did not have evidence to support operation of the controls described above and did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). For ALN 21.027, eight of the procurements sampled did not have evidence to support operation of the control of review of contracts to ensure inclusion of suspension and debarment language. Out of these eight procurements, four did not follow policies and procedures with respect to suspension and debarment (no evidence of a search of the vendor/subrecipient on SAM.gov and no inclusion of suspension and debarment language in contracts with vendors/subrecipients). Cause: The departments? controls were not adequately designed to ensure policies and procedures were followed with respect to suspension and debarment. Effect or Potential Effect: The risk of departments/agencies potentially contracting with subrecipients or vendors who are included on the suspension and debarment listing on SAM.gov is increased. During performance of our compliance testing, BDO noted none of the subrecipients or vendors for which the City?s policies and procedures were not complied with were listed as suspended or debarred parties per review of SAM.gov. Questioned Costs: None Context: For ALN 93.391, we tested a sample of five transactions totaling to $1,779,450 from a population of ten transactions totaling to $2,019,878. The results of testing disclosed all five transactions having exceptions in which DDPHE did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found DDPHE did not follow their established internal control policies and procedures with respect to suspension and debarment for all five transactions. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. For ALN 21.027, we tested a sample of 12 transactions totaling to $8,290,348 from a population of 123 transactions totaling to $34,942,425. The results of testing found eight instances in which the various departments did not ensure certifications regarding suspension and debarment were included prior to awarding the contracts as required by 2 CFR 180.300. In addition, the results of testing found four instances totaling to $5,315,476 in which the departments did not follow their established internal control policies and procedures with respect to suspension and debarment. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: The departments should follow their documented internal control procedures to ensure compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure checks for suspension and debarment have been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding and will continue to make necessary improvements to ensure that controls are implemented and operating effectively. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: One out of 25 timecards sampled did not have evidence of review by a supervisor. Cause: Established internal controls over approval of allowable costs and activities for payroll costs were not followed to ensure that the employee timecard was approved by the employee?s supervisor. Effect or Potential Effect: Payroll expenditures charged to the program may be for time not actually devoted to the program. Expenditures charged to the program may be overstated. Questioned Costs: None Context: A sample of 25 timecards totaling to $63,813 was selected from a population of 230 timecards totaling to $535,727. BDO noted one instance where there was no evidence of supervisor approval on the employee timecard. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: DHS should ensure that all timecards be subjected to review prior to payroll being processed. If supervisors are out of the office, designees should be assigned to review in their place. Views of Responsible Officials: The City agrees with the finding. DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Appendix V to 2 CFR 200, State/Local Governmentwide Central Service Cost Allocation Plans, paragraph D.2., Each major local government is also required to submit a plan to its cognizant agency for indirect costs annually. Paragraph B. of this Appendix defines major local government as a local government that receives more than $100 million in direct Federal awards. Condition: The City did not submit its central service cost allocation plan (CAP) used to claim central service costs for its various programs funded by the Department of Agriculture and Health and Human Services, passed through the State of Colorado Department of Human Services and Department of Health Care Policy and Financing to the City?s Federal cognizant agency for approval as required by the Uniform Guidance. Cause: The City was unaware of the Uniform Guidance requirement, and there were therefore no controls in place to ensure compliance. Effect or Potential Effect: The City is not in compliance with submission requirements outlined in Appendix V to 2 CFR 200 ? State / Local Governmentwide Central Service Cost Allocation Plans. Questioned Costs: Questioned costs are not determinable, as we are unable to determine if the CAP would have been approved by the Federal cognizant agency. Context: The CAP was not submitted to the Department of Transportation, the Federal cognizant agency for the City. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-016 in the 2021 report. Recommendation: The City should submit their central services cost allocation plan to the cognizant agency for indirect costs, which is defined as the Federal agency with the largest dollar value of Federal awards with a governmental unit. The City should establish written procedures concerning its central service cost allocation plan and document the Federal cognizant agency for indirect costs as well as whether it qualifies as a major local government. Views of Responsible Officials: The City agrees with the finding and the plan based on 2021 actual costs was submitted to the Federal cognizant agency on 6/16/2023. For additional information, see the City?s separate report for planned corrective actions.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR ? 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (the following is not a comprehensive list of requirements): ** Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. ** Be incorporated into the official records of the non-Federal entity. ** Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. ** Encompass both federally assisted, and all other activities compensated by the non- Federal entity on an integrated basis but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. ** Comply with the established accounting policies and practices of the non-Federal entity. ** Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: The City did not have records to adequately support payroll costs of the DDPHE Department Director allocated to the program. Cause: The City does not require employees working on multiple programs to certify their time and effort spent on each program. Time charged for the Director was based on a flat rate percentage of 25%; there was no support for the percentage used. Effect or Potential Effect: Payroll expenditures charged to the grant may be in excess of actual time and effort devoted to the program. Questioned Costs: The total amount of payroll charged to the program for the DDPHE Department Director of $26,816 (25% of the Director?s annual salary). Context: During follow-up on a prior year finding (2021-015), BDO noted the City had not yet implemented corrective action with respect to how time and effort should be recorded and had not performed periodic reviews to true-up time to the actual time and effort spent on the grant. For the year ended December 31, 2022, a portion of the Director?s salary in the amount of $26,816 was charged to the grant without documentation of time and effort. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-015 in the 2021 report. Recommendation: The Department should implement policies and procedures pertaining to employees not 100% funded by grant programs. These policies and procedures should outline how time and effort should be recorded and provide for periodic reviews to true-up time to the actual time and effort spent on the grant. Views of Responsible Officials: The City agrees with the finding and has implemented a process requiring review and approval of personnel costs that are allocated to the grant at less than 100%. For additional information, see the City?s separate report for planned corrective action.
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.512(a), the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition: The reporting package and data collection form for the year ended December 31, 2021, was not filed by the deadline of September 30, 2022, to the Federal Audit Clearinghouse. Cause: Although the Schedule and notes thereto were prepared accurately and timely, the volume of programs and coordination amongst several agencies caused the City to untimely submit the reporting package and data collection form to the Federal Audit Clearinghouse. Effect or Potential Effect: The reporting package and data collection form for the year ended December 31, 2021, was not accessible to the Federal Audit Clearinghouse in a timely manner. Questioned Costs: None Context: The reporting package and data collection form for the year ended December 31, 2021 was filed late to the Federal Audit Clearinghouse. Identification as a Repeat Finding: N/A Recommendation: We recommend the City adopt policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. Views of Responsible Officials: The City agrees with the finding and is submitting the reporting package and data collection form for the year ended December 31, 2022 by the required deadline. For additional information, see the City?s separate report for planned corrective action.