Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Internal Controls Over Activities Allowed and Allowable Costs; Internal Controls Over Cash Management– The organization should have procedures in place to ensure that grant-related activity regarding activities allowed, allowable costs, and cash management is supported by applicable accounting or performance records that is reviewed and approved by an authorized member of management. 2 CFR Section 200 Subpart E
Condition: During the course of our audit procedures performed on activities allowed, allowable costs, and cash management, it was noted that evidence of review and approval could not be produced.
Questioned costs: None
Context: We tested a sample of four out of 24 claims for reimbursement, as well as related payments made to subrecipients. For three of the four selections related to activities allowed and allowable costs, and two of the four selections related to cash management, evidence of review and approval by an appropriate member of management could not be provided. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with requirements of internal controls over compliance related to activities allowed, allowable costs, or cash management.
Cause: The Settlement did not have adequate controls and procedures in place to ensure proper review and approval took place related to the compliance requirements.
Repeat finding: This is a repeat finding (2021-008).
Recommendation: We recommend that the organization strengthen internal controls surrounding the review and approval of claims prior to submission and payments to subrecipients prior to payment by implementing and documenting formal approval on all supporting documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the absence of the Grants and Claims Manager, the Assistant Controller reviews and approves the reconciliation. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers.
Questioned costs: Unknown.
Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements.
Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring.
Repeat finding: This is a repeat finding (2021-009).
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork.
Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops.
Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation.
The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly.
Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork.
Implementation began October 2023.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Internal Controls Over Activities Allowed and Allowable Costs; Internal Controls Over Cash Management– The organization should have procedures in place to ensure that grant-related activity regarding activities allowed, allowable costs, and cash management is supported by applicable accounting or performance records that is reviewed and approved by an authorized member of management. 2 CFR Section 200 Subpart E
Condition: During the course of our audit procedures performed on activities allowed, allowable costs, and cash management, it was noted that evidence of review and approval could not be produced.
Questioned costs: None
Context: We tested a sample of four out of 24 claims for reimbursement, as well as related payments made to subrecipients. For three of the four selections related to activities allowed and allowable costs, and two of the four selections related to cash management, evidence of review and approval by an appropriate member of management could not be provided. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with requirements of internal controls over compliance related to activities allowed, allowable costs, or cash management.
Cause: The Settlement did not have adequate controls and procedures in place to ensure proper review and approval took place related to the compliance requirements.
Repeat finding: This is a repeat finding (2021-008).
Recommendation: We recommend that the organization strengthen internal controls surrounding the review and approval of claims prior to submission and payments to subrecipients prior to payment by implementing and documenting formal approval on all supporting documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the absence of the Grants and Claims Manager, the Assistant Controller reviews and approves the reconciliation. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers.
Questioned costs: Unknown.
Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements.
Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring.
Repeat finding: This is a repeat finding (2021-009).
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork.
Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops.
Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation.
The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly.
Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork.
Implementation began October 2023.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03257 Year 2022
Criteria: Procurement – Entities must have an use documented procurement procedures that conform to the federal requirements.
Condition: During the course of our audit procedures performed on procurement it was noted that the organization is not following its documented procurement procedures.
Questioned costs: None.
Context: Per the organization’s procurement procedures, purchases below $3,000 should be distributed among qualified vendors, and purchases greater than $3,000 require three written bids and documentation of how the decision to choose a specific vendor was made. We noted that although there is no contract with vendors of food for the Child and Adult Care Food Program, 82% ($227,893) of food purchases were from an individual vendor. This was comprised of multiple purchases both above and below the $3,000 threshold. However, the most recent documentation supporting a bidding process was from 2018.
Effect: Procurement procedures were not followed which allows for the possibility that federal funds were not expended equitably among qualified vendors.
Cause: The Settlement did not have internal controls in place related to procurement to ensure that documented processes are followed as required.
Repeat finding: This is a not a repeat finding.
Recommendation: We recommend that the organization adhere to its documented procurement policies.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Bids will be collected for purchases over $3,000 per the procurement requirements. The program team will review and update the policies and procedures to clearly state the bidding requirements. Program and Fiscal management will train staff and oversee the process by June 2024.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256 Year 2022
Criteria: Internal Controls Over Suspension and Debarment– The organization should have procedures in place to ensure that providers are not suspended or debarred or otherwise excluded from participating in the federal program as required by 2 CFR Section 180 Subpart C.
Condition: During the course of our audit procedures performed on suspension and debarment, it was noted that evidence of verification that providers are not suspended or debarred could not be produced.
Questioned costs: None.
Context: Management was unable to provide documentation to support verification that providers are not suspended or debarred for any of the 43 providers during 2022.
Effect: We were unable to verify internal controls over suspension and debarment were in place and functioning effectively.
Cause: The Settlement did not have internal controls in place related to verification of suspension and debarment.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that the organization strengthen internal controls surrounding the verification that providers are not suspended or debarred by implementing a policy of formal documentation of steps followed to obtain such verification.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The organization will incorporate debarment checks on providers both at enrollment into the program and annually beginning in June 2024. Debarment checks will be included in the policies and procedures (updated every January) and discussed with providers. Staff will be trained, and management will oversee the process.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Internal Controls Over Activities Allowed and Allowable Costs; Internal Controls Over Cash Management– The organization should have procedures in place to ensure that grant-related activity regarding activities allowed, allowable costs, and cash management is supported by applicable accounting or performance records that is reviewed and approved by an authorized member of management. 2 CFR Section 200 Subpart E
Condition: During the course of our audit procedures performed on activities allowed, allowable costs, and cash management, it was noted that evidence of review and approval could not be produced.
Questioned costs: None
Context: We tested a sample of four out of 24 claims for reimbursement, as well as related payments made to subrecipients. For three of the four selections related to activities allowed and allowable costs, and two of the four selections related to cash management, evidence of review and approval by an appropriate member of management could not be provided. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with requirements of internal controls over compliance related to activities allowed, allowable costs, or cash management.
Cause: The Settlement did not have adequate controls and procedures in place to ensure proper review and approval took place related to the compliance requirements.
Repeat finding: This is a repeat finding (2021-008).
Recommendation: We recommend that the organization strengthen internal controls surrounding the review and approval of claims prior to submission and payments to subrecipients prior to payment by implementing and documenting formal approval on all supporting documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the absence of the Grants and Claims Manager, the Assistant Controller reviews and approves the reconciliation. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers.
Questioned costs: Unknown.
Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements.
Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring.
Repeat finding: This is a repeat finding (2021-009).
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork.
Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops.
Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation.
The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly.
Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork.
Implementation began October 2023.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Internal Controls Over Activities Allowed and Allowable Costs; Internal Controls Over Cash Management– The organization should have procedures in place to ensure that grant-related activity regarding activities allowed, allowable costs, and cash management is supported by applicable accounting or performance records that is reviewed and approved by an authorized member of management. 2 CFR Section 200 Subpart E
Condition: During the course of our audit procedures performed on activities allowed, allowable costs, and cash management, it was noted that evidence of review and approval could not be produced.
Questioned costs: None
Context: We tested a sample of four out of 24 claims for reimbursement, as well as related payments made to subrecipients. For three of the four selections related to activities allowed and allowable costs, and two of the four selections related to cash management, evidence of review and approval by an appropriate member of management could not be provided. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with requirements of internal controls over compliance related to activities allowed, allowable costs, or cash management.
Cause: The Settlement did not have adequate controls and procedures in place to ensure proper review and approval took place related to the compliance requirements.
Repeat finding: This is a repeat finding (2021-008).
Recommendation: We recommend that the organization strengthen internal controls surrounding the review and approval of claims prior to submission and payments to subrecipients prior to payment by implementing and documenting formal approval on all supporting documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the absence of the Grants and Claims Manager, the Assistant Controller reviews and approves the reconciliation. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256, 03257 Year 2022
Criteria: Eligibility; Subrecipient Monitoring – Entities should retain all financial records, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on eligibility and subrecipient monitoring, there were instances where participant records could not be located for both children and providers.
Questioned costs: Unknown.
Context: We tested a sample of 49 of 225 children, and 11 of 43 providers for eligibility. No records for the year could be provided for 1 of the selections for compliance, and no evidence of review and approval could be provided for 6 of the records. Additionally, we tested 11 out of 43 providers for subrecipient monitoring. No records could be provided for one of the selections. The sample was not and was not intended to be statistically valid.
Effect: We were unable to verify compliance with eligibility and subrecipient monitoring requirements.
Cause: The Settlement did not have internal controls in place related to eligibility and subrecipient monitoring.
Repeat finding: This is a repeat finding (2021-009).
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork.
Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops.
Managers will complete management KidKare training to optimize electronic recordkeeping of CACFP documentation.
The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly.
Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork.
Implementation began October 2023.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Allowable costs – To receive reimbursement for the federal grant, the organization is required is required to incur qualified expenses under 2 CFR Subpart E. These expenses should be supportable by documentation and have occurred during the fiscal year.
Condition: During the course of our audit procedures performed on allowable costs, it was noted that the organization claimed reimbursement for expenses that did not exist, and there were instances where the expenses did exist, but had occurred in a prior period. Additionally, there were instances where sufficient documentation could not be provided.
Questioned costs: $325,059 related to funds requested for reimbursement for which there was no related expense. $1,508 related to expenses incurred in a prior period. $719 related to expenses for which there was insufficient support.
Context: We requested the detail of all expenditures reported in the schedule of expenditures of federal awards. The organization was not able to provide the detail of $325,059 of expenditures and determined they were reported in error. For the expenditures that could be supported, we tested 40 out of 5,418 transactions and noted that two were incurred in a prior period. The value of the sample was $42,793, and the value of the transaction related to a prior period was $1,508. Additionally, sufficient supporting documentation could not be located for the two of the 40 transactions tested totaling $719. The sample was not and was not intended to be statistically valid.
Effect: The federal agency was overbilled for reimbursement of expenditures.
Cause: The Settlement did not have adequate controls and procedures in place to ensure accuracy of expenditures requested for reimbursement.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that grant reimbursement requests be reviewed prior to submission by the Controller and/or CFAO. This review should include the verification of the existence of qualified expenditures.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
University Settlement has implemented a number of compensating controls to mitigate the risk of any future overdraws of government contract funds.
As part of the monthly process, it is required that the preparer of the invoice be separate from the reviewer and approver of the invoice and that the preparer provide an expense
report verifying the amount submitted for payment. The contract-specific monthly expense report (Director Report generated through Sage Intacct) is reviewed for accuracy and completeness by both the preparer and the reviewer. For OHS, specifically, the reviewer and approver receive both the monthly Director Report and a summary of payments received to date. The approver is either the Controller or the CFAO.
Once approved, the reimbursement request with expenses and backup documentation is submitted to the funder, who performs a final review prior to releasing payment for reimbursement.
Additionally, for year-end, the fiscal team begins the reconciliation process with the previously audited year-end A/R balances by contract. They then verify that subsequent receipts substantiate the receivable previously recorded in the books. Expenses for each contract are billed monthly by recording a receivable and revenue. Implementation began July 2022.
Program: Head Start Cluster
Assistance Listing Number: 93.600
Federal Agency: U.S. Department of Labor
Federal Award Identification: 02HE00012301C6, 02HP000313-01, 02CH11211-03, 02CH01121101C3, 02HP000066-05, 02HP00006603C3, 02CH011112-03, 02CH011112-04, CT9250143, CT9250144
Criteria: Reporting – The organization should retain all financial records, reports, supporting documents, statistical records, and all other records pertinent to the award for a period of three years from the date of submission of expenditure/claim under 2 CFR 200.334.
Condition: During the course of our audit procedures performed on reporting, it was noted that the annual report on real property required to be filed, could not be located. In addition, for the eight financial reports that were filed, the supporting information for the amounts included could not be located.
Questioned costs: None
Context: We requested all reports required to be filed for the expenditures made during the period, which included both financial and special reports, as well as the underlying documentation to support the amounts included in the reports. The organization could not locate the annual report on real property. Additionally, supporting documentation could not be located for the eight financial reports that were filed.
Effect: Reports not filed, reviewed, or signed may cause inaccurate information at the award agency and could cause delays in payments or impact future funding.
Cause: The Settlement did not have adequate controls and procedures in place to identify reporting requirements and ensure reports were filed timely.
Repeat finding: This is a repeat finding (2021-007)
Recommendation: We recommend that the organization revise its documentation storage and retention procedures to ensure maintaining of required documentation. In addition, management should implement policies and procedures to ensure required reports are completed and filed by their respective due dates as required by the grant agreement and the Uniform Guidance.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due dates reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03257 Year 2022
Criteria: Procurement – Entities must have an use documented procurement procedures that conform to the federal requirements.
Condition: During the course of our audit procedures performed on procurement it was noted that the organization is not following its documented procurement procedures.
Questioned costs: None.
Context: Per the organization’s procurement procedures, purchases below $3,000 should be distributed among qualified vendors, and purchases greater than $3,000 require three written bids and documentation of how the decision to choose a specific vendor was made. We noted that although there is no contract with vendors of food for the Child and Adult Care Food Program, 82% ($227,893) of food purchases were from an individual vendor. This was comprised of multiple purchases both above and below the $3,000 threshold. However, the most recent documentation supporting a bidding process was from 2018.
Effect: Procurement procedures were not followed which allows for the possibility that federal funds were not expended equitably among qualified vendors.
Cause: The Settlement did not have internal controls in place related to procurement to ensure that documented processes are followed as required.
Repeat finding: This is a not a repeat finding.
Recommendation: We recommend that the organization adhere to its documented procurement policies.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
Bids will be collected for purchases over $3,000 per the procurement requirements. The program team will review and update the policies and procedures to clearly state the bidding requirements. Program and Fiscal management will train staff and oversee the process by June 2024.
Program: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Federal Agency: U.S. Department of Agriculture
Pass-Through Grantor: New York State Department of Health
Award Identification: 03256 Year 2022
Criteria: Internal Controls Over Suspension and Debarment– The organization should have procedures in place to ensure that providers are not suspended or debarred or otherwise excluded from participating in the federal program as required by 2 CFR Section 180 Subpart C.
Condition: During the course of our audit procedures performed on suspension and debarment, it was noted that evidence of verification that providers are not suspended or debarred could not be produced.
Questioned costs: None.
Context: Management was unable to provide documentation to support verification that providers are not suspended or debarred for any of the 43 providers during 2022.
Effect: We were unable to verify internal controls over suspension and debarment were in place and functioning effectively.
Cause: The Settlement did not have internal controls in place related to verification of suspension and debarment.
Repeat finding: This is not a repeat finding.
Recommendation: We recommend that the organization strengthen internal controls surrounding the verification that providers are not suspended or debarred by implementing a policy of formal documentation of steps followed to obtain such verification.
Views of responsible officials and planned corrective actions: The Settlement agrees with the finding.
The organization will incorporate debarment checks on providers both at enrollment into the program and annually beginning in June 2024. Debarment checks will be included in the policies and procedures (updated every January) and discussed with providers. Staff will be trained, and management will oversee the process.