Finding 2023-002: Reporting
Federal Programs: All Programs
Criteria: Grantor requires that the Consolidated Entity submit a monthly Federal Financial Report
(FFR), SF-425, in accordance with the schedule indicated in its grant agreement, within 30 days
following the end of the prior month. Grantor also requires that the Consolidated Entity submit
programmatic reports in accordance with the schedules indicated in its grant agreements. Internal
controls should provide for these reports to report the measurement of the recipient's performance to
show achievement of program goals and objectives, share lessons learned, improve program
outcomes, and foster adoption of promising practices (2 CFR §200.301(a)).
Condition: During our audit, we noted several instances where Federal financial reports and
programmatic reports were not submitted within the deadlines outlined in the grant agreements.
Additionally, we noted some reports were still not filed as of the date of fieldwork.
Cause: The Consolidated Entity did not have the proper internal controls in place around its grants
management to ensure timely and accurate Federal financial reports as well as programmatic reports
as part of compliance with the Federal regulations.
Effect or Potential Effect: The Federal financial reports and programmatic reports according to the
Federal award(s) may not be monitored, thus having potential unallowable costs.
Questioned Costs: None noted.
Context: The Federal financial reports and programmatic reports were not submitted on a timely
basis.
Identification as a Repeat Finding: Not applicable
Recommendation: We recommend the Consolidated Entity develop proper internal controls to ensure
appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely
submission of all reports required under its Federal awards' terms and conditions.
Finding 2023-003: Use of Sole-Sourced Justification for Procurement
Federal Programs: All ProgramsCriteria: Under Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
Section 200.320(f) “Methods of procurement to be followed”, procurements by noncompetitive
proposals (i.e. sole-sourced justification) may be used only when one or more of the following
circumstances apply:
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from
competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals
in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.
Condition: Our audit work over various expenses disclosed instances of consultants and vendors
hired under the sole-sourced justification method of procurement. Although the expenses were
properly supported, the rationale for several sole-sourced selections was not properly documented
and/or not always appeared to be reasonable.
Cause: The Consolidated Entity was not in full compliance with sole-sourced justification requirements,
as stated above, during the year ended September 30, 2023.
Effect or Potential Effect: The Consolidated Entity could enter into contractual arrangements
whereby they are not receiving the best value for the organization and/or in which there exists conflicts
of interest. Ultimately, transparency with respect to these transactions could be compromised if the
proper procurement actions are not followed.
Questioned Costs: None noted.
Context: The Consolidated Entity failed to consistently document its justification with respect to solesourced
according to the above-noted requirements.
Identification as a Repeat Finding: 2022-004
Recommendation: We recommend that the Consolidated Entity limit its use of sole-sourced
justification based on the above-noted requirements. In cases where sole-sourced is appropriate, we
recommend that the actions (or lack of actions) be properly and fully documented. The importance in
maintaining a record of each procurement action is to support the Consolidated Entity’s due diligence
process. We also believe this process helps identify any actual or potential conflicts of interest with
prospective vendors and contractors.
Finding 2023-002: Reporting
Federal Programs: All Programs
Criteria: Grantor requires that the Consolidated Entity submit a monthly Federal Financial Report
(FFR), SF-425, in accordance with the schedule indicated in its grant agreement, within 30 days
following the end of the prior month. Grantor also requires that the Consolidated Entity submit
programmatic reports in accordance with the schedules indicated in its grant agreements. Internal
controls should provide for these reports to report the measurement of the recipient's performance to
show achievement of program goals and objectives, share lessons learned, improve program
outcomes, and foster adoption of promising practices (2 CFR §200.301(a)).
Condition: During our audit, we noted several instances where Federal financial reports and
programmatic reports were not submitted within the deadlines outlined in the grant agreements.
Additionally, we noted some reports were still not filed as of the date of fieldwork.
Cause: The Consolidated Entity did not have the proper internal controls in place around its grants
management to ensure timely and accurate Federal financial reports as well as programmatic reports
as part of compliance with the Federal regulations.
Effect or Potential Effect: The Federal financial reports and programmatic reports according to the
Federal award(s) may not be monitored, thus having potential unallowable costs.
Questioned Costs: None noted.
Context: The Federal financial reports and programmatic reports were not submitted on a timely
basis.
Identification as a Repeat Finding: Not applicable
Recommendation: We recommend the Consolidated Entity develop proper internal controls to ensure
appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely
submission of all reports required under its Federal awards' terms and conditions.
Finding 2023-003: Use of Sole-Sourced Justification for Procurement
Federal Programs: All ProgramsCriteria: Under Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
Section 200.320(f) “Methods of procurement to be followed”, procurements by noncompetitive
proposals (i.e. sole-sourced justification) may be used only when one or more of the following
circumstances apply:
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from
competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals
in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.
Condition: Our audit work over various expenses disclosed instances of consultants and vendors
hired under the sole-sourced justification method of procurement. Although the expenses were
properly supported, the rationale for several sole-sourced selections was not properly documented
and/or not always appeared to be reasonable.
Cause: The Consolidated Entity was not in full compliance with sole-sourced justification requirements,
as stated above, during the year ended September 30, 2023.
Effect or Potential Effect: The Consolidated Entity could enter into contractual arrangements
whereby they are not receiving the best value for the organization and/or in which there exists conflicts
of interest. Ultimately, transparency with respect to these transactions could be compromised if the
proper procurement actions are not followed.
Questioned Costs: None noted.
Context: The Consolidated Entity failed to consistently document its justification with respect to solesourced
according to the above-noted requirements.
Identification as a Repeat Finding: 2022-004
Recommendation: We recommend that the Consolidated Entity limit its use of sole-sourced
justification based on the above-noted requirements. In cases where sole-sourced is appropriate, we
recommend that the actions (or lack of actions) be properly and fully documented. The importance in
maintaining a record of each procurement action is to support the Consolidated Entity’s due diligence
process. We also believe this process helps identify any actual or potential conflicts of interest with
prospective vendors and contractors.
Finding 2023-002: Reporting
Federal Programs: All Programs
Criteria: Grantor requires that the Consolidated Entity submit a monthly Federal Financial Report
(FFR), SF-425, in accordance with the schedule indicated in its grant agreement, within 30 days
following the end of the prior month. Grantor also requires that the Consolidated Entity submit
programmatic reports in accordance with the schedules indicated in its grant agreements. Internal
controls should provide for these reports to report the measurement of the recipient's performance to
show achievement of program goals and objectives, share lessons learned, improve program
outcomes, and foster adoption of promising practices (2 CFR §200.301(a)).
Condition: During our audit, we noted several instances where Federal financial reports and
programmatic reports were not submitted within the deadlines outlined in the grant agreements.
Additionally, we noted some reports were still not filed as of the date of fieldwork.
Cause: The Consolidated Entity did not have the proper internal controls in place around its grants
management to ensure timely and accurate Federal financial reports as well as programmatic reports
as part of compliance with the Federal regulations.
Effect or Potential Effect: The Federal financial reports and programmatic reports according to the
Federal award(s) may not be monitored, thus having potential unallowable costs.
Questioned Costs: None noted.
Context: The Federal financial reports and programmatic reports were not submitted on a timely
basis.
Identification as a Repeat Finding: Not applicable
Recommendation: We recommend the Consolidated Entity develop proper internal controls to ensure
appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely
submission of all reports required under its Federal awards' terms and conditions.
Finding 2023-003: Use of Sole-Sourced Justification for Procurement
Federal Programs: All ProgramsCriteria: Under Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
Section 200.320(f) “Methods of procurement to be followed”, procurements by noncompetitive
proposals (i.e. sole-sourced justification) may be used only when one or more of the following
circumstances apply:
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from
competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals
in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.
Condition: Our audit work over various expenses disclosed instances of consultants and vendors
hired under the sole-sourced justification method of procurement. Although the expenses were
properly supported, the rationale for several sole-sourced selections was not properly documented
and/or not always appeared to be reasonable.
Cause: The Consolidated Entity was not in full compliance with sole-sourced justification requirements,
as stated above, during the year ended September 30, 2023.
Effect or Potential Effect: The Consolidated Entity could enter into contractual arrangements
whereby they are not receiving the best value for the organization and/or in which there exists conflicts
of interest. Ultimately, transparency with respect to these transactions could be compromised if the
proper procurement actions are not followed.
Questioned Costs: None noted.
Context: The Consolidated Entity failed to consistently document its justification with respect to solesourced
according to the above-noted requirements.
Identification as a Repeat Finding: 2022-004
Recommendation: We recommend that the Consolidated Entity limit its use of sole-sourced
justification based on the above-noted requirements. In cases where sole-sourced is appropriate, we
recommend that the actions (or lack of actions) be properly and fully documented. The importance in
maintaining a record of each procurement action is to support the Consolidated Entity’s due diligence
process. We also believe this process helps identify any actual or potential conflicts of interest with
prospective vendors and contractors.
Finding 2023-002: Reporting
Federal Programs: All Programs
Criteria: Grantor requires that the Consolidated Entity submit a monthly Federal Financial Report
(FFR), SF-425, in accordance with the schedule indicated in its grant agreement, within 30 days
following the end of the prior month. Grantor also requires that the Consolidated Entity submit
programmatic reports in accordance with the schedules indicated in its grant agreements. Internal
controls should provide for these reports to report the measurement of the recipient's performance to
show achievement of program goals and objectives, share lessons learned, improve program
outcomes, and foster adoption of promising practices (2 CFR §200.301(a)).
Condition: During our audit, we noted several instances where Federal financial reports and
programmatic reports were not submitted within the deadlines outlined in the grant agreements.
Additionally, we noted some reports were still not filed as of the date of fieldwork.
Cause: The Consolidated Entity did not have the proper internal controls in place around its grants
management to ensure timely and accurate Federal financial reports as well as programmatic reports
as part of compliance with the Federal regulations.
Effect or Potential Effect: The Federal financial reports and programmatic reports according to the
Federal award(s) may not be monitored, thus having potential unallowable costs.
Questioned Costs: None noted.
Context: The Federal financial reports and programmatic reports were not submitted on a timely
basis.
Identification as a Repeat Finding: Not applicable
Recommendation: We recommend the Consolidated Entity develop proper internal controls to ensure
appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely
submission of all reports required under its Federal awards' terms and conditions.
Finding 2023-003: Use of Sole-Sourced Justification for Procurement
Federal Programs: All ProgramsCriteria: Under Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
Section 200.320(f) “Methods of procurement to be followed”, procurements by noncompetitive
proposals (i.e. sole-sourced justification) may be used only when one or more of the following
circumstances apply:
The item is available only from a single source;
The public exigency or emergency for the requirement will not permit a delay resulting from
competitive solicitation;
The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals
in response to a written request from the non-Federal entity; or
After solicitation of a number of sources, competition is determined inadequate.
Condition: Our audit work over various expenses disclosed instances of consultants and vendors
hired under the sole-sourced justification method of procurement. Although the expenses were
properly supported, the rationale for several sole-sourced selections was not properly documented
and/or not always appeared to be reasonable.
Cause: The Consolidated Entity was not in full compliance with sole-sourced justification requirements,
as stated above, during the year ended September 30, 2023.
Effect or Potential Effect: The Consolidated Entity could enter into contractual arrangements
whereby they are not receiving the best value for the organization and/or in which there exists conflicts
of interest. Ultimately, transparency with respect to these transactions could be compromised if the
proper procurement actions are not followed.
Questioned Costs: None noted.
Context: The Consolidated Entity failed to consistently document its justification with respect to solesourced
according to the above-noted requirements.
Identification as a Repeat Finding: 2022-004
Recommendation: We recommend that the Consolidated Entity limit its use of sole-sourced
justification based on the above-noted requirements. In cases where sole-sourced is appropriate, we
recommend that the actions (or lack of actions) be properly and fully documented. The importance in
maintaining a record of each procurement action is to support the Consolidated Entity’s due diligence
process. We also believe this process helps identify any actual or potential conflicts of interest with
prospective vendors and contractors.