Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.
Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.