Audit 303304

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-003 Cash Management Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context We tested a sample of four cash drawdowns out of thirty-seven drawdowns totaling $140,926, our audit procedures revealed $13,600 were not disbursed timely. In addition, our SEFA reconciliation procedures revealed that $197,249 had not been disbursed timely at the end of the fiscal year. Criteria Uniform Guidance requires that non-federal entities minimize the time elapsing between the transfer of funds and disbursements by the non-federal entity. Cause CMSDC did not reconcile expenditures to cash drawdowns. Effect CMSDC did not comply with Uniform Guidance and closed the year with a grant advance of $197,249. Recommendation We recommend that CMSDC updates it policies and procedures to include procedures for reconciling expenditures to cash drawdowns. In addition, we recommend that CMSDC reconciles expenditures and cash drawdowns on a monthly basis. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.

Finding 2021-002, 2020-001 Noncompliance with Uniform Guidance's Report Submission Requirements - Repeat Finding Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC did not submit its audit and data collection form to the Audit Clearinghouse within nine months after the end of the audit period. Criteria Uniform Guidance requires that audits must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Cause In 2021, CMSDC experienced turnover in key personnel. In the third quarter of 2021, CMSDC hired an external CPA firm (comptroller) to conduct the accounting and assist with the financial close and reporting process. The 2020 audit was completed in March 2023. Due to time constraints, the 2021 audit and data collection form were not submitted in the required timeline. Effect CMSDC did not comply with Uniform Guidance's requirement for report submission. Recommendation We recommend that management completes the financial close and reporting process three months after end of the fiscal year, to allow for timely completion of audits and submissions of data collection forms. Organization's Management Response See corrective action plan.

Finding 2021-004 Procurement, Suspension & Debarment Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Condition/Context CMSDC was not able to produce evidence that demonstrates it documented its history of procurement, or that it performed suspension or debarment checks. Criteria The Uniform Guidance requires recipients (i.e., CMSDC) to have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards set forth in Title 2, Section 200.318 of the Code of Federal Regulations, including, recipients must maintain records sufficient to detail the history of procurement. Cause In 2021, CMSDC experienced turnover in key personnel. Current personnel was not able to provide documentation of its history of procurement or evidence that it performed suspension and debarment checks. Effect CMSDC did not comply with the procurement standards for documentation, suspension and debarment set forth in the Uniform Guidance. Recommendation We recommend that CMSDC performs procurement in accordance with Uniform Guidance, updates its Accounting Policies and Procedures Manual for procurement to ensure it aligns to Uniform Guidance, and that CMSDC adheres to such policies. Organization's Management Response See corrective plan.