Audit 302460

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

2022-006 Significant Deficiency in Internal Controls over Compliance – Cash Management Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over cash management to comply with terms and conditions of the Federal award. Per CFR 200.305(b), for cost reimbursement awards, the timing of cash draws shall be as close as administratively feasible to the actual disbursements of program costs. Additionally, per 2 CFR 200.334, “financial records, supporting documents . . . and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that reimbursement requests were accurate and supported by expenditures incurred prior to the drawdown request. Monthly reimbursement requests were not reviewed by an individual, other than the preparer, to ensure the amount requested agreed to the supporting records. Additionally, the supporting records used to prepare the reimbursement requests were not retained. Reconciliation and monitoring activities were not in place to ensure amounts requested matched recalculated expenditure totals between periods. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of cash management requirements and documentation. Context: See condition. Effect: Due to the condition of the supporting records and lack of an effective tracking system regarding expenditures already reimbursed, there is potential that CCS could have been reimbursed for the same expense twice or that drawdowns occurred before expenses are incurred. Records had to be recreated in order to complete our audit procedures. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that reimbursement requests are accurate and supported by expenditures incurred. Further, we recommend management develop a tracking spreadsheet to record and monitor monthly reimbursement amounts, as well as the total amount drawndown, over the award’s period of performance. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-004 Material Weakness in Internal Controls over Compliance – Single Audit Report Submission Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: New Criteria: Per 2 CFR 200.512(a), the single audit reporting package must be submitted within nine months after the end of the audit period, unless approved by the oversight agency. Condition: CCS’s fiscal year 2022 single audit package was not submitted within nine months after the end of the audit period. Cause: CCS did not have appropriate internal control policies and procedures in place to ensure that the single audit package was submitted within nine months after year end. Effective: CCS was not in compliance with federal requirements related to the single audit report submission. Questioned costs: None. Perspective: CCS’s single audit package was not submitted within nine months after the end of the period under audit. Recommendation: To ensure compliance with the Uniform Guidance, CCS should ensure that the audit is performed in a timely manner to submit the single audit reporting package within nine months after the end of the audit period. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.

2022-006 Significant Deficiency in Internal Controls over Compliance – Cash Management Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over cash management to comply with terms and conditions of the Federal award. Per CFR 200.305(b), for cost reimbursement awards, the timing of cash draws shall be as close as administratively feasible to the actual disbursements of program costs. Additionally, per 2 CFR 200.334, “financial records, supporting documents . . . and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that reimbursement requests were accurate and supported by expenditures incurred prior to the drawdown request. Monthly reimbursement requests were not reviewed by an individual, other than the preparer, to ensure the amount requested agreed to the supporting records. Additionally, the supporting records used to prepare the reimbursement requests were not retained. Reconciliation and monitoring activities were not in place to ensure amounts requested matched recalculated expenditure totals between periods. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of cash management requirements and documentation. Context: See condition. Effect: Due to the condition of the supporting records and lack of an effective tracking system regarding expenditures already reimbursed, there is potential that CCS could have been reimbursed for the same expense twice or that drawdowns occurred before expenses are incurred. Records had to be recreated in order to complete our audit procedures. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that reimbursement requests are accurate and supported by expenditures incurred. Further, we recommend management develop a tracking spreadsheet to record and monitor monthly reimbursement amounts, as well as the total amount drawndown, over the award’s period of performance. View of responsible officials: Management concurs with this finding, see corrective action plan.