2022-001 Data Collection Form Submission Delay
Criteria: Per 2 CFR 200.512(a)(1), the audit package and the data collection form shall be submitted 30 days after receipt of the auditor's report(s), or 9 months after the end of the fiscal year —whichever comes first.
Condition: For the year ended June 30, 2021, the audit package and data collection form was not submitted within the required timeline.
Cause: For the year ended June 30, 2021, the financial audit was not completed until September 2022.
Effect: This is considered to be a significant deficiency in controls over compliance.
Questioned Costs: None noted.
Context: The Organization’s financial audit was not completed within the required period and the data collection form was not submitted to the Federal Clearinghouse website within 9 months after the end of the fiscal year.
Repeat Finding: No.
Recommendation: We recommend implementing a control, such as having 2 people involved in the process, that will ensure that the data collection form is submitted timely.
Views of Responsible
Officials: Management agrees with the finding and a response is included in the corrective action plan.
2022-002 Report Submission Delay
Program: 17.270 Reentry Employment Opportunities
Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit quarterly financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any quarterly financial report.
Condition: During our audit, we identified one quarterly financial report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date. Cause: During the reporting period, the Organization’s management was not aware that a user application was needed to be submitted and approved in order to gain access to the Payment Management System (PMS). The delay in obtaining PMS access caused management’s delay in submitting the required quarterly financial report.
Effect: Report was not submitted to the COR in a timely manner and a request for extension of the due date was not made.
Questioned Costs: None noted.
Context: The report was due to the COR within 45 days of the reporting period end and was submitted one day after the stated due date.
Repeat Finding: No.
Recommendation: When timely submission may not be possible, the Organization should request an extension from the COR by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, the Organization should submit reports by the initial stated due date.
Views of Responsible
Officials: Management agrees with the finding and a response is included in the corrective action plan.
2022-003 Procurement Policy
Criteria: The Uniform Guidance requires that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: During our audit, we inquired with management regarding their procurement policy that was implemented in April 2022. While policy exists, there were no specific procedures noted in the procurement policy to ensure that vendors are not suspended or debarred.
Cause: The Organization’s procurement policy did not include procedures to ensure that vendors are suspended or debarred.
Effect: Not having a procedure in place could result in payments to suspended or debarred entities.
Questioned Costs: None noted.
Context: Ensuring that the Organization’s vendors are not suspended or debarred should be part of the expense approval process. Auditors tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: The Organization should amend the policy to adhere to the stated criteria.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2022-001 Data Collection Form Submission Delay
Criteria: Per 2 CFR 200.512(a)(1), the audit package and the data collection form shall be submitted 30 days after receipt of the auditor's report(s), or 9 months after the end of the fiscal year —whichever comes first.
Condition: For the year ended June 30, 2021, the audit package and data collection form was not submitted within the required timeline.
Cause: For the year ended June 30, 2021, the financial audit was not completed until September 2022.
Effect: This is considered to be a significant deficiency in controls over compliance.
Questioned Costs: None noted.
Context: The Organization’s financial audit was not completed within the required period and the data collection form was not submitted to the Federal Clearinghouse website within 9 months after the end of the fiscal year.
Repeat Finding: No.
Recommendation: We recommend implementing a control, such as having 2 people involved in the process, that will ensure that the data collection form is submitted timely.
Views of Responsible
Officials: Management agrees with the finding and a response is included in the corrective action plan.
2022-002 Report Submission Delay
Program: 17.270 Reentry Employment Opportunities
Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit quarterly financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any quarterly financial report.
Condition: During our audit, we identified one quarterly financial report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date. Cause: During the reporting period, the Organization’s management was not aware that a user application was needed to be submitted and approved in order to gain access to the Payment Management System (PMS). The delay in obtaining PMS access caused management’s delay in submitting the required quarterly financial report.
Effect: Report was not submitted to the COR in a timely manner and a request for extension of the due date was not made.
Questioned Costs: None noted.
Context: The report was due to the COR within 45 days of the reporting period end and was submitted one day after the stated due date.
Repeat Finding: No.
Recommendation: When timely submission may not be possible, the Organization should request an extension from the COR by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, the Organization should submit reports by the initial stated due date.
Views of Responsible
Officials: Management agrees with the finding and a response is included in the corrective action plan.
2022-003 Procurement Policy
Criteria: The Uniform Guidance requires that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: During our audit, we inquired with management regarding their procurement policy that was implemented in April 2022. While policy exists, there were no specific procedures noted in the procurement policy to ensure that vendors are not suspended or debarred.
Cause: The Organization’s procurement policy did not include procedures to ensure that vendors are suspended or debarred.
Effect: Not having a procedure in place could result in payments to suspended or debarred entities.
Questioned Costs: None noted.
Context: Ensuring that the Organization’s vendors are not suspended or debarred should be part of the expense approval process. Auditors tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: The Organization should amend the policy to adhere to the stated criteria.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.