Audit 310511

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number 2021-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.

Finding Number 2021-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.

Finding Number 2021-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.

Finding Number 2021-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.