2023-002 Material Weakness in Internal Control and Compliance over Allowable Costs and Activities Related to Payroll Expenditures
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Additionally, the Organization may only charge to the federal award, allowable costs incurred during the period of performance. Condition - During our testing of payroll expenditures, we identified expenditures that were incurred outside of the award contract period of performance and included in reimbursement requests submitted to the pass-through agency.
Cause - The Organization did not maintain proper adherence to internal controls over the federal program as it relates to tracking and allocating the expenditures of federal awards. This includes allocating costs incurred outside of the contract period to the federal program and requesting reimbursement from the agency. The pass-through agency allows the Organization to report expenditures on both a cash and accrual basis, if reimbursement requests of those expenditures are not duplicated. This could lead to confusion when requesting reimbursements for expenditures that may fall outside of the period of performance covered by the award contract.
Effect - Noncompliance with the allowable costs and activities of the federal award as described in both the award contract and OMB Circular A-122, Cost Principles for Non-Profit Organizations, could result in reimbursement denials and ultimately lead to the payback of costs or loss of future funding.
Questioned Costs - Immaterial amount.
Context - As part of our audit procedures, we sampled two months of expense reimbursement requests which included payroll expenditures incurred to test internal controls over compliance and compliance with the allowable costs and activities of federal awards.
During our testing of payroll expenditures, we noted the following deviations:
- For three of seven payroll selections from our statistically valid sample, costs included amounts incurred outside of the period of performance covered by the award contract for the period from July 2022 through September 2022.
o Upon further examination, we identified that all 27 employees at the Solis-Cohen site, included four days’ worth of payroll expenditures incurred prior to the award contract period beginning July 2022, but were submitted for reimbursement under that contract.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-003. Recommendation - We strongly recommend the Organization choose one basis of reporting (cash or accrual) and apply consistently to expenditures submitted for reimbursement. Additionally, procedures should be implemented by the Organization to track and report expenditures eligible for reimbursement based on when it is incurred and retain all related supporting documentation.
Views of Responsible Officials and Planned Corrective Actions - The questioned costs were immaterial and relate to a pay period that was split across the fiscal year (6/27/22 to 7/8/22, with a pay date of 7/15/22). Reports to the funder for the year ending 6/30/22 were due on 7/10/22, before all payroll information and supporting documentation for this pay period was available. Therefore, the full pay period was included in the July reimbursement report. This practice was approved by the funder.
Moving forward, the Organization will be more cognizant of accrual dates for payroll reporting and submit a true-up as needed to ensure that payroll costs are correctly allocated at the end of the fiscal year. Additionally, in May 2024, the Organization will be implementing a new electronic payroll system that will allow us to obtain this information more quickly at the close of each fiscal year to complete billing reports.
2023-002 Material Weakness in Internal Control and Compliance over Allowable Costs and Activities Related to Payroll Expenditures
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Additionally, the Organization may only charge to the federal award, allowable costs incurred during the period of performance. Condition - During our testing of payroll expenditures, we identified expenditures that were incurred outside of the award contract period of performance and included in reimbursement requests submitted to the pass-through agency.
Cause - The Organization did not maintain proper adherence to internal controls over the federal program as it relates to tracking and allocating the expenditures of federal awards. This includes allocating costs incurred outside of the contract period to the federal program and requesting reimbursement from the agency. The pass-through agency allows the Organization to report expenditures on both a cash and accrual basis, if reimbursement requests of those expenditures are not duplicated. This could lead to confusion when requesting reimbursements for expenditures that may fall outside of the period of performance covered by the award contract.
Effect - Noncompliance with the allowable costs and activities of the federal award as described in both the award contract and OMB Circular A-122, Cost Principles for Non-Profit Organizations, could result in reimbursement denials and ultimately lead to the payback of costs or loss of future funding.
Questioned Costs - Immaterial amount.
Context - As part of our audit procedures, we sampled two months of expense reimbursement requests which included payroll expenditures incurred to test internal controls over compliance and compliance with the allowable costs and activities of federal awards.
During our testing of payroll expenditures, we noted the following deviations:
- For three of seven payroll selections from our statistically valid sample, costs included amounts incurred outside of the period of performance covered by the award contract for the period from July 2022 through September 2022.
o Upon further examination, we identified that all 27 employees at the Solis-Cohen site, included four days’ worth of payroll expenditures incurred prior to the award contract period beginning July 2022, but were submitted for reimbursement under that contract.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-003. Recommendation - We strongly recommend the Organization choose one basis of reporting (cash or accrual) and apply consistently to expenditures submitted for reimbursement. Additionally, procedures should be implemented by the Organization to track and report expenditures eligible for reimbursement based on when it is incurred and retain all related supporting documentation.
Views of Responsible Officials and Planned Corrective Actions - The questioned costs were immaterial and relate to a pay period that was split across the fiscal year (6/27/22 to 7/8/22, with a pay date of 7/15/22). Reports to the funder for the year ending 6/30/22 were due on 7/10/22, before all payroll information and supporting documentation for this pay period was available. Therefore, the full pay period was included in the July reimbursement report. This practice was approved by the funder.
Moving forward, the Organization will be more cognizant of accrual dates for payroll reporting and submit a true-up as needed to ensure that payroll costs are correctly allocated at the end of the fiscal year. Additionally, in May 2024, the Organization will be implementing a new electronic payroll system that will allow us to obtain this information more quickly at the close of each fiscal year to complete billing reports.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-004 Material Weakness in Internal Control and Compliance over Eligibility
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require that, among other things, participants in the program meet certain eligibility requirements. In compliance with 2 CFR Part 200, Subpart D, Performance and Financial Monitoring and Reporting § 200.329, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award, must be retained for a period of three years from the date of submission of the final expenditure report.
Condition - During our testing of participant eligibility, we noted that certain required documentation for participation in the program had not been obtained and retained in the participant’s file.
Cause - There is a lack of sufficient adherence to internal controls over document retention, independent review and approval of required items, and the organization and accuracy of supporting documentation.
Effect - Lack of supporting documentation could result in the Organization being required to return funds received for providing services to ineligible participants. Additionally, the funding agency could impose compliance actions against the Organization.
Questioned Costs - $180,071 Context - As part of our audit procedures, we sampled a total of 25 participants to test internal controls over compliance and compliance with the eligibility of federal awards.
During our testing of participant eligibility, we noted the following deviations:
- Three selections in our statistically valid sample lacked appropriate documentation to substantiate the participants’ health records were obtained within 60 days of enrollment in the program and subsequently retained by the Organization.
Repeat Finding - No
Recommendation - The Organization should implement controls and procedures for obtaining and retaining supporting documentation for all participants as required by the specific provisions of each contract or grant agreement pertaining to the federal program. Procedures should include the implementation of controls over document retention that would prevent acceptance into the program until all supporting documentation has been verified by an individual independent of the admission process.
Views of Responsible Officials and Planned Corrective Actions - Out of over 182 compliance records requested, the Organization was unable to provide 3 health assessments, all other requested documentation was provided. The missing health assessments were for high school students, who are not required to provide them to attend school and often do not have access to updated health assessments. We have been directed by the funding agency never to exclude these youth from participation for an inability to obtain a health assessment.
BGCP has already taken steps to address these issues. The funding agency, PHMC, has begun sending monthly compliance reports. Over the last three months, we have collected 42% of missing health assessments organization-wide. Additionally, on our recent FY24 Admin review from PHMC, which included a full compliance report, all of our sites received overall scores of above 95%. We will continue to monitor compliance and follow-up with youth and families to complete needed items.
2023-004 Material Weakness in Internal Control and Compliance over Eligibility
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require that, among other things, participants in the program meet certain eligibility requirements. In compliance with 2 CFR Part 200, Subpart D, Performance and Financial Monitoring and Reporting § 200.329, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award, must be retained for a period of three years from the date of submission of the final expenditure report.
Condition - During our testing of participant eligibility, we noted that certain required documentation for participation in the program had not been obtained and retained in the participant’s file.
Cause - There is a lack of sufficient adherence to internal controls over document retention, independent review and approval of required items, and the organization and accuracy of supporting documentation.
Effect - Lack of supporting documentation could result in the Organization being required to return funds received for providing services to ineligible participants. Additionally, the funding agency could impose compliance actions against the Organization.
Questioned Costs - $180,071 Context - As part of our audit procedures, we sampled a total of 25 participants to test internal controls over compliance and compliance with the eligibility of federal awards.
During our testing of participant eligibility, we noted the following deviations:
- Three selections in our statistically valid sample lacked appropriate documentation to substantiate the participants’ health records were obtained within 60 days of enrollment in the program and subsequently retained by the Organization.
Repeat Finding - No
Recommendation - The Organization should implement controls and procedures for obtaining and retaining supporting documentation for all participants as required by the specific provisions of each contract or grant agreement pertaining to the federal program. Procedures should include the implementation of controls over document retention that would prevent acceptance into the program until all supporting documentation has been verified by an individual independent of the admission process.
Views of Responsible Officials and Planned Corrective Actions - Out of over 182 compliance records requested, the Organization was unable to provide 3 health assessments, all other requested documentation was provided. The missing health assessments were for high school students, who are not required to provide them to attend school and often do not have access to updated health assessments. We have been directed by the funding agency never to exclude these youth from participation for an inability to obtain a health assessment.
BGCP has already taken steps to address these issues. The funding agency, PHMC, has begun sending monthly compliance reports. Over the last three months, we have collected 42% of missing health assessments organization-wide. Additionally, on our recent FY24 Admin review from PHMC, which included a full compliance report, all of our sites received overall scores of above 95%. We will continue to monitor compliance and follow-up with youth and families to complete needed items.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-002 Material Weakness in Internal Control and Compliance over Allowable Costs and Activities Related to Payroll Expenditures
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Additionally, the Organization may only charge to the federal award, allowable costs incurred during the period of performance. Condition - During our testing of payroll expenditures, we identified expenditures that were incurred outside of the award contract period of performance and included in reimbursement requests submitted to the pass-through agency.
Cause - The Organization did not maintain proper adherence to internal controls over the federal program as it relates to tracking and allocating the expenditures of federal awards. This includes allocating costs incurred outside of the contract period to the federal program and requesting reimbursement from the agency. The pass-through agency allows the Organization to report expenditures on both a cash and accrual basis, if reimbursement requests of those expenditures are not duplicated. This could lead to confusion when requesting reimbursements for expenditures that may fall outside of the period of performance covered by the award contract.
Effect - Noncompliance with the allowable costs and activities of the federal award as described in both the award contract and OMB Circular A-122, Cost Principles for Non-Profit Organizations, could result in reimbursement denials and ultimately lead to the payback of costs or loss of future funding.
Questioned Costs - Immaterial amount.
Context - As part of our audit procedures, we sampled two months of expense reimbursement requests which included payroll expenditures incurred to test internal controls over compliance and compliance with the allowable costs and activities of federal awards.
During our testing of payroll expenditures, we noted the following deviations:
- For three of seven payroll selections from our statistically valid sample, costs included amounts incurred outside of the period of performance covered by the award contract for the period from July 2022 through September 2022.
o Upon further examination, we identified that all 27 employees at the Solis-Cohen site, included four days’ worth of payroll expenditures incurred prior to the award contract period beginning July 2022, but were submitted for reimbursement under that contract.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-003. Recommendation - We strongly recommend the Organization choose one basis of reporting (cash or accrual) and apply consistently to expenditures submitted for reimbursement. Additionally, procedures should be implemented by the Organization to track and report expenditures eligible for reimbursement based on when it is incurred and retain all related supporting documentation.
Views of Responsible Officials and Planned Corrective Actions - The questioned costs were immaterial and relate to a pay period that was split across the fiscal year (6/27/22 to 7/8/22, with a pay date of 7/15/22). Reports to the funder for the year ending 6/30/22 were due on 7/10/22, before all payroll information and supporting documentation for this pay period was available. Therefore, the full pay period was included in the July reimbursement report. This practice was approved by the funder.
Moving forward, the Organization will be more cognizant of accrual dates for payroll reporting and submit a true-up as needed to ensure that payroll costs are correctly allocated at the end of the fiscal year. Additionally, in May 2024, the Organization will be implementing a new electronic payroll system that will allow us to obtain this information more quickly at the close of each fiscal year to complete billing reports.
2023-002 Material Weakness in Internal Control and Compliance over Allowable Costs and Activities Related to Payroll Expenditures
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Additionally, the Organization may only charge to the federal award, allowable costs incurred during the period of performance. Condition - During our testing of payroll expenditures, we identified expenditures that were incurred outside of the award contract period of performance and included in reimbursement requests submitted to the pass-through agency.
Cause - The Organization did not maintain proper adherence to internal controls over the federal program as it relates to tracking and allocating the expenditures of federal awards. This includes allocating costs incurred outside of the contract period to the federal program and requesting reimbursement from the agency. The pass-through agency allows the Organization to report expenditures on both a cash and accrual basis, if reimbursement requests of those expenditures are not duplicated. This could lead to confusion when requesting reimbursements for expenditures that may fall outside of the period of performance covered by the award contract.
Effect - Noncompliance with the allowable costs and activities of the federal award as described in both the award contract and OMB Circular A-122, Cost Principles for Non-Profit Organizations, could result in reimbursement denials and ultimately lead to the payback of costs or loss of future funding.
Questioned Costs - Immaterial amount.
Context - As part of our audit procedures, we sampled two months of expense reimbursement requests which included payroll expenditures incurred to test internal controls over compliance and compliance with the allowable costs and activities of federal awards.
During our testing of payroll expenditures, we noted the following deviations:
- For three of seven payroll selections from our statistically valid sample, costs included amounts incurred outside of the period of performance covered by the award contract for the period from July 2022 through September 2022.
o Upon further examination, we identified that all 27 employees at the Solis-Cohen site, included four days’ worth of payroll expenditures incurred prior to the award contract period beginning July 2022, but were submitted for reimbursement under that contract.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-003. Recommendation - We strongly recommend the Organization choose one basis of reporting (cash or accrual) and apply consistently to expenditures submitted for reimbursement. Additionally, procedures should be implemented by the Organization to track and report expenditures eligible for reimbursement based on when it is incurred and retain all related supporting documentation.
Views of Responsible Officials and Planned Corrective Actions - The questioned costs were immaterial and relate to a pay period that was split across the fiscal year (6/27/22 to 7/8/22, with a pay date of 7/15/22). Reports to the funder for the year ending 6/30/22 were due on 7/10/22, before all payroll information and supporting documentation for this pay period was available. Therefore, the full pay period was included in the July reimbursement report. This practice was approved by the funder.
Moving forward, the Organization will be more cognizant of accrual dates for payroll reporting and submit a true-up as needed to ensure that payroll costs are correctly allocated at the end of the fiscal year. Additionally, in May 2024, the Organization will be implementing a new electronic payroll system that will allow us to obtain this information more quickly at the close of each fiscal year to complete billing reports.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-003 Material Weakness in Internal Control and Compliance over the Schedule of Expenditures of Federal Awards
Federal Program: All
Criteria or Specific Requirement - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 508 - Auditee Responsibilities, requires the auditee to prepare a schedule of expenditures of federal awards. The schedule must provide the total federal awards expended for each individual federal program and the Assistance Listings Number.
Condition - While performing audit procedures on the initial schedule of expenditures of federal awards (“SEFA”) provided, we noted several errors in the reported amounts as expenditures of federal awards.
Cause - The internal controls in place to report expenditures of federal awards for reporting on the SEFA were not operating effectively.
Effect - The initial SEFA did not accurately reflect the expenditures of federal awards for several programs.
Questioned Costs - None
Context - In performing audit procedures over the initial SEFA, we identified discrepancies for multiple programs where the expenditures of federal awards listed on the initial SEFA did not agree with confirmations received from the corresponding cognizant agency or reconcile to general ledger activity and supporting documentation. While the Organization was ultimately able to reconcile program expenditures and provide an accurate SEFA, there were significant adjustments required resulting in adjustments in excess of $560,000 from the originally prepared SEFA to what is reported in these consolidated financial statements.
Additionally, in performing audit procedures over grants, we identified two programs where the expenditures of federal awards were not included in the original SEFA. The final and correct amounts for those programs were $39,250. Our procedures also identified a program fully funded by state funds that was erroneously included on the SEFA totaling $119,960. This has been excluded from the SEFA in these consolidated financial statements.
Repeat Finding - This is a repeat finding from the prior year. See prior year finding 2022-004.
Recommendation - We recommend that management review the current procedures in place for preparation of the SEFA. We also recommend that the SEFA be prepared by a qualified individual in the accounting department, and that review is performed by the Chief Financial Officer, or an equivalent individual.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding.
Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. However, moving forward, management will meet quarterly to update the tracking of federal expenditures. Additionally, management will communicate with funding entities bi-annually to verify what portions of the funding are federal. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
2023-004 Material Weakness in Internal Control and Compliance over Eligibility
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require that, among other things, participants in the program meet certain eligibility requirements. In compliance with 2 CFR Part 200, Subpart D, Performance and Financial Monitoring and Reporting § 200.329, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award, must be retained for a period of three years from the date of submission of the final expenditure report.
Condition - During our testing of participant eligibility, we noted that certain required documentation for participation in the program had not been obtained and retained in the participant’s file.
Cause - There is a lack of sufficient adherence to internal controls over document retention, independent review and approval of required items, and the organization and accuracy of supporting documentation.
Effect - Lack of supporting documentation could result in the Organization being required to return funds received for providing services to ineligible participants. Additionally, the funding agency could impose compliance actions against the Organization.
Questioned Costs - $180,071 Context - As part of our audit procedures, we sampled a total of 25 participants to test internal controls over compliance and compliance with the eligibility of federal awards.
During our testing of participant eligibility, we noted the following deviations:
- Three selections in our statistically valid sample lacked appropriate documentation to substantiate the participants’ health records were obtained within 60 days of enrollment in the program and subsequently retained by the Organization.
Repeat Finding - No
Recommendation - The Organization should implement controls and procedures for obtaining and retaining supporting documentation for all participants as required by the specific provisions of each contract or grant agreement pertaining to the federal program. Procedures should include the implementation of controls over document retention that would prevent acceptance into the program until all supporting documentation has been verified by an individual independent of the admission process.
Views of Responsible Officials and Planned Corrective Actions - Out of over 182 compliance records requested, the Organization was unable to provide 3 health assessments, all other requested documentation was provided. The missing health assessments were for high school students, who are not required to provide them to attend school and often do not have access to updated health assessments. We have been directed by the funding agency never to exclude these youth from participation for an inability to obtain a health assessment.
BGCP has already taken steps to address these issues. The funding agency, PHMC, has begun sending monthly compliance reports. Over the last three months, we have collected 42% of missing health assessments organization-wide. Additionally, on our recent FY24 Admin review from PHMC, which included a full compliance report, all of our sites received overall scores of above 95%. We will continue to monitor compliance and follow-up with youth and families to complete needed items.
2023-004 Material Weakness in Internal Control and Compliance over Eligibility
Federal Agency: U.S. Department of Health and Human Services
Federal Program: 93.558, Temporary Assistance for Needy Families Cluster
Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require that, among other things, participants in the program meet certain eligibility requirements. In compliance with 2 CFR Part 200, Subpart D, Performance and Financial Monitoring and Reporting § 200.329, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award, must be retained for a period of three years from the date of submission of the final expenditure report.
Condition - During our testing of participant eligibility, we noted that certain required documentation for participation in the program had not been obtained and retained in the participant’s file.
Cause - There is a lack of sufficient adherence to internal controls over document retention, independent review and approval of required items, and the organization and accuracy of supporting documentation.
Effect - Lack of supporting documentation could result in the Organization being required to return funds received for providing services to ineligible participants. Additionally, the funding agency could impose compliance actions against the Organization.
Questioned Costs - $180,071 Context - As part of our audit procedures, we sampled a total of 25 participants to test internal controls over compliance and compliance with the eligibility of federal awards.
During our testing of participant eligibility, we noted the following deviations:
- Three selections in our statistically valid sample lacked appropriate documentation to substantiate the participants’ health records were obtained within 60 days of enrollment in the program and subsequently retained by the Organization.
Repeat Finding - No
Recommendation - The Organization should implement controls and procedures for obtaining and retaining supporting documentation for all participants as required by the specific provisions of each contract or grant agreement pertaining to the federal program. Procedures should include the implementation of controls over document retention that would prevent acceptance into the program until all supporting documentation has been verified by an individual independent of the admission process.
Views of Responsible Officials and Planned Corrective Actions - Out of over 182 compliance records requested, the Organization was unable to provide 3 health assessments, all other requested documentation was provided. The missing health assessments were for high school students, who are not required to provide them to attend school and often do not have access to updated health assessments. We have been directed by the funding agency never to exclude these youth from participation for an inability to obtain a health assessment.
BGCP has already taken steps to address these issues. The funding agency, PHMC, has begun sending monthly compliance reports. Over the last three months, we have collected 42% of missing health assessments organization-wide. Additionally, on our recent FY24 Admin review from PHMC, which included a full compliance report, all of our sites received overall scores of above 95%. We will continue to monitor compliance and follow-up with youth and families to complete needed items.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.
2023-005 Deficiency in Compliance Over Timely Report Submissions
Federal Program: All
Criteria or Specific Requirement - 45 CFR § 75.512, Report Submission, requires completion of an audit and submission of the data collection form and reporting package within the earlier of thirty calendar days after receipt of the auditors’ report, or nine months after the end of the audit period.
Condition - The audit and data collection form are being submitted after the required due date.
Cause - The Organization did not maintain appropriate levels of staff to ensure compliance with regulatory filing requirements.
Effect - Noncompliance with the requirements of 45 CFR § 75.512. There is a potential for suspension or cessation of federal funding under the federal award. Questioned Cost - To be determined by the grantor.
Context - We reviewed the audit submission date in comparison to the required due date.
Repeat Finding - No
Recommendation - The Organization should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year-end.
View of Responsible Officials and Planned Corrective Actions - Management concurs with the findings. The outside accounting firm has increased staffing needs and implemented a more rigorous reporting and reconciliation schedule as shown in the response to 2023-001.