Audit 297263

FY End
2023-06-30
Total Expended
$3.14M
Findings
8
Programs
10
Organization: Municipality of Catano (PR)
Year: 2023 Accepted: 2024-03-25

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
384108 2023-002 Significant Deficiency Yes L
384109 2023-002 Significant Deficiency Yes L
384110 2023-003 Significant Deficiency - L
384111 2023-004 Significant Deficiency - G
960550 2023-002 Significant Deficiency Yes L
960551 2023-002 Significant Deficiency Yes L
960552 2023-003 Significant Deficiency - L
960553 2023-004 Significant Deficiency - G

Contacts

Name Title Type
JB9YLJZMNP73 Honoris MacHado Marquez Auditee
7877880404 Angel A. Lopez Vega Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred. De Minimis Rate Used: N Rate Explanation: The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards includes the federal grant activity of the Municipality under programs of the federal government for the year ended June 30, 2023. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from the amounts presented in, or used in the preparation of, the basic financial statements. Because the schedule presents only a selected portion of the operations of the Municipality, it is not intended to and does not present the financial position and changes in net assets of the Municipality.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred. De Minimis Rate Used: N Rate Explanation: The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred.
Title: RELATIONSHIP TO BASIC FINANCIAL STATEMENTS Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred. De Minimis Rate Used: N Rate Explanation: The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance. A reconciliation of total expenditures related to federal programs included in the statement of revenues, expenditures, and changes in fund balances – governmental funds to total expenditures included in the schedule of expenditures of federal awards is as follows:
Title: ASSISTANCE LISTING NUMBER AND PASS-THROUGH ENTITY IDENTIFYING NUMBER Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred. De Minimis Rate Used: N Rate Explanation: The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance. The Assistance Listing Number (ALN), formerly known as the Catalog of Federal Domestic Assistance (CFDA) Number, is a five-digit number assigned in the awarding document for a federal assistance award mechanism, including federal grants and cooperative agreements. Assistance listings are detailed public descriptions of federal programs that provide grants, loans, scholarships, insurance, and other types of assistance awards. The SAM.gov assistance listing is the publicly available online database showing all available Federally-funded programs. State or local government redistributions of federal awards to the Municipality, known as “pass–through awards”, should be treated by the Municipality as though they were received directly from the federal government. The Uniform Guidance requires the schedule to include the name of the pass–through entity and the identifying number assigned by the pass-through entity for the federal awards received as a subrecipient. Numbers identified as N/A are not applicable and numbers identified as N/AV are not available.
Title: INDIRECT COST RATE Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Expenditures are recognized when the related liability is incurred, following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for the following programs are recognized based on other unique requirements: • Public assistance grants (FEMA). Expenditures are recognized in the period when: (1) FEMA has approved the PW, and (2) eligible expenditures are incurred. • Loan or loan guarantee Programs. Expenditures equal the value of new loans made or received during the audit period plus the beginning of the audit period balance of outstanding loans from previous years for which the federal government imposes continuing compliance requirements. For loans with no imposed continuing compliance requirements, expenditures are recognized when the related costs financed with loan proceeds are incurred. De Minimis Rate Used: N Rate Explanation: The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance. The Municipality elected not to use the ten (10) percent of de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Finding Reference 2023-002 Federal Agency: U.S. Department of the Treasury Pass-through Agency: Puerto Rico Fiscal Agency and Financial Advisory Authority Program: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing No. 21.027) Compliance Requirement: Reporting – Special Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During the fiscal year, the Municipality administered funds from the Coronavirus State and Local Fiscal Recovery Funds, this allocation was granted directly from the Federal government and through Puerto Rico Fiscal Agency and Financial Advisory Authority, respectively. In our Reporting Test, we evaluated three monthly reports submitted to the Puerto Rico Fiscal Agency and Financial Advisory Authority. We found that the Municipality submitted two of the three reports late. Also, we evaluated the annual Project and Expenditure Report submitted to the U.S. Department of Treasury. We found that the Municipality reported as current expenditures expenses that were reported incurred in the report from the prior period. Criteria The Municipal Strengthening Fund Transfer Agreement, Clause 5.1, states that the Transferee shall submit reports as the Transferor determines are needed to verify use of the funds and compliance with conditions that are imposed on the Transfer, and such reports shall be in such form, with such content, as specified by the Transferor in the Transfer Plan and future program instructions directed to all Recipients. The Transfer Plan, on Exhibit A, establishes that starting on the 15th day of the month following receipt of the funds, and by the 15th day of each month, the Transferee will submit a Use of Funds Report for the prior month’s expenses. Also, on the Municipal Strengthening Fund Program Guidelines, the Puerto Rico Fiscal Agency and Financial Advisory Authority specified on the Reporting Requirements Section that the recipients are required to submit monthly financial reports using the reporting template provided by the program. In addition to the contract agreement with the Puerto Rico Fiscal Agency and Financial Advisory Authority, the Municipality had an agreement with the U.S. Department of Treasury to receive funds direct funds as a Non-entitlement and County Unit. We determined that the Municipality submitted the required annual report in time. The Coronavirus State and Local Fiscal Recovery Funds - Compliance and Reporting Guidance, Part I, Section 10 (d), states that all recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Appropriate accounting records must be maintained for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, controls need to be established to ensure the completion and timely submission of all mandatory performance and/or compliance reporting. Cause of Condition There is a lack of knowledge and training for the personnel assigned. Additionally, the Municipality does not have adequate monitoring for the activity and the reports. Effect of Condition The program is not in compliance with the Reporting Requirements as established in the contract agreement and guidelines. Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency such as: (1) submitting the reports during the 15th day of each month, where the fund expenses of the previous month will be reported as incurred. Also, the Municipality should establish a process to validate that the amounts reported agree with the accounting records of the corresponding period reported. This will ensure better control of the program. Questioned Cost None. Prior Year Finding This finding is similar to prior year finding 2022-003. Views of Responsible Officials and Planned Corrective Action We concur with the finding. The Municipality of Cataño (Federal Programs Office), as a corrective action, will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector
Finding Reference 2023-002 Federal Agency: U.S. Department of the Treasury Pass-through Agency: Puerto Rico Fiscal Agency and Financial Advisory Authority Program: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing No. 21.027) Compliance Requirement: Reporting – Special Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During the fiscal year, the Municipality administered funds from the Coronavirus State and Local Fiscal Recovery Funds, this allocation was granted directly from the Federal government and through Puerto Rico Fiscal Agency and Financial Advisory Authority, respectively. In our Reporting Test, we evaluated three monthly reports submitted to the Puerto Rico Fiscal Agency and Financial Advisory Authority. We found that the Municipality submitted two of the three reports late. Also, we evaluated the annual Project and Expenditure Report submitted to the U.S. Department of Treasury. We found that the Municipality reported as current expenditures expenses that were reported incurred in the report from the prior period. Criteria The Municipal Strengthening Fund Transfer Agreement, Clause 5.1, states that the Transferee shall submit reports as the Transferor determines are needed to verify use of the funds and compliance with conditions that are imposed on the Transfer, and such reports shall be in such form, with such content, as specified by the Transferor in the Transfer Plan and future program instructions directed to all Recipients. The Transfer Plan, on Exhibit A, establishes that starting on the 15th day of the month following receipt of the funds, and by the 15th day of each month, the Transferee will submit a Use of Funds Report for the prior month’s expenses. Also, on the Municipal Strengthening Fund Program Guidelines, the Puerto Rico Fiscal Agency and Financial Advisory Authority specified on the Reporting Requirements Section that the recipients are required to submit monthly financial reports using the reporting template provided by the program. In addition to the contract agreement with the Puerto Rico Fiscal Agency and Financial Advisory Authority, the Municipality had an agreement with the U.S. Department of Treasury to receive funds direct funds as a Non-entitlement and County Unit. We determined that the Municipality submitted the required annual report in time. The Coronavirus State and Local Fiscal Recovery Funds - Compliance and Reporting Guidance, Part I, Section 10 (d), states that all recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Appropriate accounting records must be maintained for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, controls need to be established to ensure the completion and timely submission of all mandatory performance and/or compliance reporting. Cause of Condition There is a lack of knowledge and training for the personnel assigned. Additionally, the Municipality does not have adequate monitoring for the activity and the reports. Effect of Condition The program is not in compliance with the Reporting Requirements as established in the contract agreement and guidelines. Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency such as: (1) submitting the reports during the 15th day of each month, where the fund expenses of the previous month will be reported as incurred. Also, the Municipality should establish a process to validate that the amounts reported agree with the accounting records of the corresponding period reported. This will ensure better control of the program. Questioned Cost None. Prior Year Finding This finding is similar to prior year finding 2022-003. Views of Responsible Officials and Planned Corrective Action We concur with the finding. The Municipality of Cataño (Federal Programs Office), as a corrective action, will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector
Finding Reference 2023-003 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Puerto Rico Department of Family Program: Child Care and Development Block Grant (Assistance Listing No. 93.575) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During our audit procedures, we found that the Program did not submit all the annual closing reports or were submitted late to the pass-through entity, as required by the contract agreement. Criteria 45 CFR Part 98.67 (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. Also, the contract agreement states in Clause eleven (11) that the Municipality is responsible for the presentation of the trial balance and annual partial closing report fifteen (15) calendar days after the end of the contract. Ninety (90) days after, the Municipality should liquidate all obligations and present to the pass-through entity the final annual closing report (CC-006). Cause of Condition The Program does not have effective internal controls to ensure that the required documentation and reports are submitted to the pass-through agency in the requested time frame. There was a change in the personnel in charge of the fiscal area of the program. Therefore, reports have been submitted late or haven’t been submitted yet. Effect of Condition The Program is not in compliance with 45 CFR Part 98.67- Fiscal Requirements (c) (1) (2). Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency. This will ensure better control of the program. Questioned Cost None. Prior Year Finding No. Views of Responsible Officials and Planned Corrective Action We concur with the finding. In the month of January 2024, the Municipality of Cataño submitted a Letter to the ACUDEN Agency requesting additional time to be able to submit a closure report. This request is due to the fact that said agency has not disbursed the approved funds to the Program, to be able to carry out the breakdown of expenses and corresponding payments. To date we have not received a response to this request. The Municipality of Cataño (Federal Programs Office) undertakes to follow up with the relevant agency in future occasions to receive a response when an extension is requested for a compliance report. Implementation Date: Fiscal year 2023-2024 Responsible Person: Mrs. Yolanda Maldonado Oliver, Federal Programs Director
Finding Reference 2023-004 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Puerto Rico Department of Family Program: Child Care and Development Block Grant (Assistance Listing No. 93.575) Compliance Requirement: Earmarking (G) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition In our Earmarking Test, we found that the Program did not comply with the quality earmark limitation that requires the program to spend at least nine percent (9%) of the funds on quality activities and at least an additional three percent (3%) on quality improvement for infants and toddlers on the program. Also, we found that the Program did not comply with the direct spending earmark limitation that requires the program to spend not less than seventy percent (70%) to fund direct services. Criteria 45 CFR, Subpart F, Section 98.50 (b) (1) states that of the aggregate amount of funds expended by a State or Territory, no less than seven percent in fiscal years 2016 and 2017, eight percent in fiscal years 2018 and 2019, and nine percent in fiscal year 2020 and each succeeding fiscal year shall be used for activities designed to improve the quality of child care services and increase parental options for, and access to, high-quality child care as described at 45 CFR Subpart F, Section 98.53. Section 98.50 (b) (2) states that no less than three percent in fiscal year 2017 and each succeeding fiscal year shall be used to carry out activities as such activities relate to the quality of care for infants and toddlers. Also, section 98.50 (b) (3) states that nothing in this section shall preclude the State or Territory from reserving a larger percentage of funds to carry out activities described in paragraphs (b) (1) and (2) of Section 98.50. 45 CFR, Subpart F, Section 95.50 (d) states of the aggregate amount of funds expended, no more than five percent may be used for administrative activities as described in 45 CFR 98.54. 45 CFR, Subpart F, Section 95.50 (f) (2) states that from Discretionary amounts provided for a fiscal year, the Lead Agency shall use not less than 70 percent to fund direct services (provided by the Lead Agency). Cause of Condition The program’s budget, approved by the pass-through entity, was not distributed according to the cost limitations required for the administrative, quality and direct costs. Therefore, the amounts spent per category of expenditure did not meet the minimum amounts. Effect of Condition The program is not in compliance with 45 CFR, Subpart F, Section 98.50. Recommendation We recommend the Program’s Management to request to the pass-through entity a revision of the approved budgeted amounts in order to make all the required adjustments to comply with the program cost limitations. Questioned Cost None. Prior Year Finding No. Views of Responsible Officials and Planned Corrective Action We do not concur with the finding. This finding is not applicable because what is stated about the description in the approved budget is not stipulated by the Municipality of Cataño, which is the one being audited. This description is designated from ACUDEN. Implementation date: Fiscal year 2023-2024 Responsible official: Mrs. Lymara Salgado, Child Care Program Director
Finding Reference 2023-002 Federal Agency: U.S. Department of the Treasury Pass-through Agency: Puerto Rico Fiscal Agency and Financial Advisory Authority Program: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing No. 21.027) Compliance Requirement: Reporting – Special Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During the fiscal year, the Municipality administered funds from the Coronavirus State and Local Fiscal Recovery Funds, this allocation was granted directly from the Federal government and through Puerto Rico Fiscal Agency and Financial Advisory Authority, respectively. In our Reporting Test, we evaluated three monthly reports submitted to the Puerto Rico Fiscal Agency and Financial Advisory Authority. We found that the Municipality submitted two of the three reports late. Also, we evaluated the annual Project and Expenditure Report submitted to the U.S. Department of Treasury. We found that the Municipality reported as current expenditures expenses that were reported incurred in the report from the prior period. Criteria The Municipal Strengthening Fund Transfer Agreement, Clause 5.1, states that the Transferee shall submit reports as the Transferor determines are needed to verify use of the funds and compliance with conditions that are imposed on the Transfer, and such reports shall be in such form, with such content, as specified by the Transferor in the Transfer Plan and future program instructions directed to all Recipients. The Transfer Plan, on Exhibit A, establishes that starting on the 15th day of the month following receipt of the funds, and by the 15th day of each month, the Transferee will submit a Use of Funds Report for the prior month’s expenses. Also, on the Municipal Strengthening Fund Program Guidelines, the Puerto Rico Fiscal Agency and Financial Advisory Authority specified on the Reporting Requirements Section that the recipients are required to submit monthly financial reports using the reporting template provided by the program. In addition to the contract agreement with the Puerto Rico Fiscal Agency and Financial Advisory Authority, the Municipality had an agreement with the U.S. Department of Treasury to receive funds direct funds as a Non-entitlement and County Unit. We determined that the Municipality submitted the required annual report in time. The Coronavirus State and Local Fiscal Recovery Funds - Compliance and Reporting Guidance, Part I, Section 10 (d), states that all recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Appropriate accounting records must be maintained for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, controls need to be established to ensure the completion and timely submission of all mandatory performance and/or compliance reporting. Cause of Condition There is a lack of knowledge and training for the personnel assigned. Additionally, the Municipality does not have adequate monitoring for the activity and the reports. Effect of Condition The program is not in compliance with the Reporting Requirements as established in the contract agreement and guidelines. Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency such as: (1) submitting the reports during the 15th day of each month, where the fund expenses of the previous month will be reported as incurred. Also, the Municipality should establish a process to validate that the amounts reported agree with the accounting records of the corresponding period reported. This will ensure better control of the program. Questioned Cost None. Prior Year Finding This finding is similar to prior year finding 2022-003. Views of Responsible Officials and Planned Corrective Action We concur with the finding. The Municipality of Cataño (Federal Programs Office), as a corrective action, will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector
Finding Reference 2023-002 Federal Agency: U.S. Department of the Treasury Pass-through Agency: Puerto Rico Fiscal Agency and Financial Advisory Authority Program: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing No. 21.027) Compliance Requirement: Reporting – Special Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During the fiscal year, the Municipality administered funds from the Coronavirus State and Local Fiscal Recovery Funds, this allocation was granted directly from the Federal government and through Puerto Rico Fiscal Agency and Financial Advisory Authority, respectively. In our Reporting Test, we evaluated three monthly reports submitted to the Puerto Rico Fiscal Agency and Financial Advisory Authority. We found that the Municipality submitted two of the three reports late. Also, we evaluated the annual Project and Expenditure Report submitted to the U.S. Department of Treasury. We found that the Municipality reported as current expenditures expenses that were reported incurred in the report from the prior period. Criteria The Municipal Strengthening Fund Transfer Agreement, Clause 5.1, states that the Transferee shall submit reports as the Transferor determines are needed to verify use of the funds and compliance with conditions that are imposed on the Transfer, and such reports shall be in such form, with such content, as specified by the Transferor in the Transfer Plan and future program instructions directed to all Recipients. The Transfer Plan, on Exhibit A, establishes that starting on the 15th day of the month following receipt of the funds, and by the 15th day of each month, the Transferee will submit a Use of Funds Report for the prior month’s expenses. Also, on the Municipal Strengthening Fund Program Guidelines, the Puerto Rico Fiscal Agency and Financial Advisory Authority specified on the Reporting Requirements Section that the recipients are required to submit monthly financial reports using the reporting template provided by the program. In addition to the contract agreement with the Puerto Rico Fiscal Agency and Financial Advisory Authority, the Municipality had an agreement with the U.S. Department of Treasury to receive funds direct funds as a Non-entitlement and County Unit. We determined that the Municipality submitted the required annual report in time. The Coronavirus State and Local Fiscal Recovery Funds - Compliance and Reporting Guidance, Part I, Section 10 (d), states that all recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Appropriate accounting records must be maintained for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, controls need to be established to ensure the completion and timely submission of all mandatory performance and/or compliance reporting. Cause of Condition There is a lack of knowledge and training for the personnel assigned. Additionally, the Municipality does not have adequate monitoring for the activity and the reports. Effect of Condition The program is not in compliance with the Reporting Requirements as established in the contract agreement and guidelines. Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency such as: (1) submitting the reports during the 15th day of each month, where the fund expenses of the previous month will be reported as incurred. Also, the Municipality should establish a process to validate that the amounts reported agree with the accounting records of the corresponding period reported. This will ensure better control of the program. Questioned Cost None. Prior Year Finding This finding is similar to prior year finding 2022-003. Views of Responsible Officials and Planned Corrective Action We concur with the finding. The Municipality of Cataño (Federal Programs Office), as a corrective action, will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector
Finding Reference 2023-003 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Puerto Rico Department of Family Program: Child Care and Development Block Grant (Assistance Listing No. 93.575) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition During our audit procedures, we found that the Program did not submit all the annual closing reports or were submitted late to the pass-through entity, as required by the contract agreement. Criteria 45 CFR Part 98.67 (c) Fiscal control and accounting procedures shall be sufficient to permit: (1) Preparation of reports required by the Secretary under this subpart and under subpart H; and (2) The tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provisions of this part. Also, the contract agreement states in Clause eleven (11) that the Municipality is responsible for the presentation of the trial balance and annual partial closing report fifteen (15) calendar days after the end of the contract. Ninety (90) days after, the Municipality should liquidate all obligations and present to the pass-through entity the final annual closing report (CC-006). Cause of Condition The Program does not have effective internal controls to ensure that the required documentation and reports are submitted to the pass-through agency in the requested time frame. There was a change in the personnel in charge of the fiscal area of the program. Therefore, reports have been submitted late or haven’t been submitted yet. Effect of Condition The Program is not in compliance with 45 CFR Part 98.67- Fiscal Requirements (c) (1) (2). Recommendation We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and develop complete and accurate reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the pass-through agency. This will ensure better control of the program. Questioned Cost None. Prior Year Finding No. Views of Responsible Officials and Planned Corrective Action We concur with the finding. In the month of January 2024, the Municipality of Cataño submitted a Letter to the ACUDEN Agency requesting additional time to be able to submit a closure report. This request is due to the fact that said agency has not disbursed the approved funds to the Program, to be able to carry out the breakdown of expenses and corresponding payments. To date we have not received a response to this request. The Municipality of Cataño (Federal Programs Office) undertakes to follow up with the relevant agency in future occasions to receive a response when an extension is requested for a compliance report. Implementation Date: Fiscal year 2023-2024 Responsible Person: Mrs. Yolanda Maldonado Oliver, Federal Programs Director
Finding Reference 2023-004 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Puerto Rico Department of Family Program: Child Care and Development Block Grant (Assistance Listing No. 93.575) Compliance Requirement: Earmarking (G) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Statement of Condition In our Earmarking Test, we found that the Program did not comply with the quality earmark limitation that requires the program to spend at least nine percent (9%) of the funds on quality activities and at least an additional three percent (3%) on quality improvement for infants and toddlers on the program. Also, we found that the Program did not comply with the direct spending earmark limitation that requires the program to spend not less than seventy percent (70%) to fund direct services. Criteria 45 CFR, Subpart F, Section 98.50 (b) (1) states that of the aggregate amount of funds expended by a State or Territory, no less than seven percent in fiscal years 2016 and 2017, eight percent in fiscal years 2018 and 2019, and nine percent in fiscal year 2020 and each succeeding fiscal year shall be used for activities designed to improve the quality of child care services and increase parental options for, and access to, high-quality child care as described at 45 CFR Subpart F, Section 98.53. Section 98.50 (b) (2) states that no less than three percent in fiscal year 2017 and each succeeding fiscal year shall be used to carry out activities as such activities relate to the quality of care for infants and toddlers. Also, section 98.50 (b) (3) states that nothing in this section shall preclude the State or Territory from reserving a larger percentage of funds to carry out activities described in paragraphs (b) (1) and (2) of Section 98.50. 45 CFR, Subpart F, Section 95.50 (d) states of the aggregate amount of funds expended, no more than five percent may be used for administrative activities as described in 45 CFR 98.54. 45 CFR, Subpart F, Section 95.50 (f) (2) states that from Discretionary amounts provided for a fiscal year, the Lead Agency shall use not less than 70 percent to fund direct services (provided by the Lead Agency). Cause of Condition The program’s budget, approved by the pass-through entity, was not distributed according to the cost limitations required for the administrative, quality and direct costs. Therefore, the amounts spent per category of expenditure did not meet the minimum amounts. Effect of Condition The program is not in compliance with 45 CFR, Subpart F, Section 98.50. Recommendation We recommend the Program’s Management to request to the pass-through entity a revision of the approved budgeted amounts in order to make all the required adjustments to comply with the program cost limitations. Questioned Cost None. Prior Year Finding No. Views of Responsible Officials and Planned Corrective Action We do not concur with the finding. This finding is not applicable because what is stated about the description in the approved budget is not stipulated by the Municipality of Cataño, which is the one being audited. This description is designated from ACUDEN. Implementation date: Fiscal year 2023-2024 Responsible official: Mrs. Lymara Salgado, Child Care Program Director