Audit 312368

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.

FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.

FINDING 2022-207The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Type of Finding: Significant DeficiencyAssistance Listing Title: Sport Fish Restoration; Wildlife Restoration and Basic Hunter EducationAssistance Listing Number: 15.605; 15.611Federal Award Number: F19AF00026; F19AF00093; F22AF00371; F14AF01014; F20AF11918; F22AF00372; F20AF11578; F21AF03374; F21AF03986; F21AF03986Program Year: January 1, 2019 ? December 31, 2021; January 1, 2019 ? December 31, 2021; January 1, 2022 ? December 31, 2024; August 1, 2014 ? June 30, 2022; July 1, 2020 ? June 30, 2021; January 1, 2022 ? December 31, 2024; July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023; July 1, 2021 ? June 30, 2022; July 1, 2021 ? June 30, 2022Federal Agency: Department of the InteriorCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR ?200.510(b), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502, and? Total amount provided to subrecipients from each federal programCondition: The Department completed a SEFA closing package to report federal grant expenditures. The amount reported as passed through to subrecipients was overstated by a total of $331,500. The Sport Fish Restoration Program (Assistance Listing Number 15.605) payments to subrecipients were overstated by $10,513, and the Wildlife Restoration Program (Assistance Listing Number 16.611) payments to subrecipients were overstated by $320,987.Cause: The Department made payments to entities who received subawards under the grants and also provided specific vendor services for the grants. The person compiling the SEFA closing package was new to that process and included all payments to the entities as payments to subrecipients, even though some of the payments were for vendor services and should not have been included. The SEFA closing package was reviewed for accuracy prior to being submitted to the Office of the State Controller, but this review did not detect the error.Effect: The Department?s SEFA closing package overstated the amount passed through to subrecipients by $331,500. The total expenditures for the grant programs were $7,196,361 in the Sport Fish Restoration Program and $15,479,486 in the Wildlife Restoration Program. Subrecipient payments make up a small portion of the overall grant expenditures comprising $31,539 in the Sport Fish Restoration Program (0.44 percent of the total) and $520,630 in the Wildlife Restoration Program (3.36 percent of the total). The effect is limited because the trivial materiality for the statewide SEFA is $1.9 million. The Department submitted a corrected SEFA closing package to correct the error.Recommendation: We recommend that the Department design and implement procedures to ensure amounts passed through to subrecipients are accurately reported on the SEFA closing package.Management?s View: The Department has reviewed its reporting of subrecipient expenditures on the State Fiscal Year 2022 Schedule of Expenditure of Federal Awards (?SEFA?) and agrees with the finding that an overstatement was made.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA. This corrective action plan will be implemented by the end of August 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-207The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Type of Finding: Significant DeficiencyAssistance Listing Title: Sport Fish Restoration; Wildlife Restoration and Basic Hunter EducationAssistance Listing Number: 15.605; 15.611Federal Award Number: F19AF00026; F19AF00093; F22AF00371; F14AF01014; F20AF11918; F22AF00372; F20AF11578; F21AF03374; F21AF03986; F21AF03986Program Year: January 1, 2019 ? December 31, 2021; January 1, 2019 ? December 31, 2021; January 1, 2022 ? December 31, 2024; August 1, 2014 ? June 30, 2022; July 1, 2020 ? June 30, 2021; January 1, 2022 ? December 31, 2024; July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023; July 1, 2021 ? June 30, 2022; July 1, 2021 ? June 30, 2022Federal Agency: Department of the InteriorCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR ?200.510(b), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502, and? Total amount provided to subrecipients from each federal programCondition: The Department completed a SEFA closing package to report federal grant expenditures. The amount reported as passed through to subrecipients was overstated by a total of $331,500. The Sport Fish Restoration Program (Assistance Listing Number 15.605) payments to subrecipients were overstated by $10,513, and the Wildlife Restoration Program (Assistance Listing Number 16.611) payments to subrecipients were overstated by $320,987.Cause: The Department made payments to entities who received subawards under the grants and also provided specific vendor services for the grants. The person compiling the SEFA closing package was new to that process and included all payments to the entities as payments to subrecipients, even though some of the payments were for vendor services and should not have been included. The SEFA closing package was reviewed for accuracy prior to being submitted to the Office of the State Controller, but this review did not detect the error.Effect: The Department?s SEFA closing package overstated the amount passed through to subrecipients by $331,500. The total expenditures for the grant programs were $7,196,361 in the Sport Fish Restoration Program and $15,479,486 in the Wildlife Restoration Program. Subrecipient payments make up a small portion of the overall grant expenditures comprising $31,539 in the Sport Fish Restoration Program (0.44 percent of the total) and $520,630 in the Wildlife Restoration Program (3.36 percent of the total). The effect is limited because the trivial materiality for the statewide SEFA is $1.9 million. The Department submitted a corrected SEFA closing package to correct the error.Recommendation: We recommend that the Department design and implement procedures to ensure amounts passed through to subrecipients are accurately reported on the SEFA closing package.Management?s View: The Department has reviewed its reporting of subrecipient expenditures on the State Fiscal Year 2022 Schedule of Expenditure of Federal Awards (?SEFA?) and agrees with the finding that an overstatement was made.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA. This corrective action plan will be implemented by the end of August 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-205An expenditure was made by the Department for unallowable activities from the Elementary and Secondary School Emergency Relief (ESSER) program.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Education Stabilization Fund - ARPA ESSER IIIAssistance Listing Number: 84.425UFederal Award Number: S425U210043Program Year: March 24, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Activities allowed or unallowedQuestioned Costs: Known: $2,270.65; Likely: $71,576Criteria: The Department awards and passes ESSER funds to school districts or local educational agencies (LEAs) in the State. The LEAs may use ESSER funds for a wide range of activities to address needs arising from the coronavirus pandemic. The ESSER funding is made available by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and the American Rescue Plan (ARP) Act. The CARES Act (Section 18003 (d)) provides a broad list of LEA allowable activities. The CRRSA Act (Section 313(3)) includes additional LEA allowable uses of funds, in particular addressing learning loss; preparing schools for reopening; and testing, repairing, and upgrading projects to improve air quality in school buildings. The ARP Act (Section 2001(e)) further expands LEA allowable uses of funds to include providing mental health support, developing strategies, and implementing public health protocols on reopening and operating schools to effectively maintain the health and safety of students, educators, and staff.Condition: During our review of ESSER grant expenditures for allowable activities and costs, we selected a sample of 60 transactions to evaluate for compliance, substantive accuracy, and adequately designed and applied internal controls. We noted one transaction for $12,374.83 that included $2,270.65 for staff lunches, which are unallowable as a cost paid for by this grant.Cause: A subrecipient of the Department requested reimbursement from the ESSER grant in June 2022 for employee salaries and benefits, supplies, materials, and staff meals. Staff meals are unallowable to the ESSER grant. This unallowable activity was not identified during the Department?s review of the transaction. Department personnel reviewing and approving the reimbursement request believed that, based upon the wording in the request, the transaction was for different purposes and allowable under the ESSER grant. However, further review and inquiring to the LEA after the audit exception was identified supported that the expenditure was not allowed.Effect: The Department reimbursed unallowed costs of $2,271 which results in projected questioned costs of $71,576 for the ESSER program.Recommendation: We recommend that the Department strengthen control procedures to ensure all expenditures are allowable prior to approving reimbursement to LEAs.Management?s View: The Department agrees with this finding.Corrective Action: When the Elementary and Secondary School Emergency Relief Funds {ESSER) were first awarded, it was not required that districts attach any documentation to their Grant Reimbursement Application {GRA) requests. Federal Programs will start requiring that all requests coming in through the GRA system have supporting documentation attached as of July 1, 2023, which is the beginning of our next fiscal cycle. We will announce this new procedure through emails and during our state-wide Consolidated Federal and State Grant Application training in April and May 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We agree with the Department that it is important to provide the additional guidance received from the federal grantors to the subrecipients, we want to emphasize that it is the Department?s responsibility to ensure that only allowable costs are reimbursed to the LEAs, and to implement appropriate internal control activities, including adequate supporting documentation, to ensure compliance with this requirement.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-208State Opioid Response program performance progress reports did not have documentation to support completion of a review for accuracy and compliance prior to submission.Type of Finding: Material WeaknessAssistance Listing Title: Opioid STRAssistance Listing Number: 93.788Federal Award Number: H79TI083282; H79TI081727Program Year: September 30, 2020 ? September 29, 2023; September 30, 2018 ? September 29, 2021Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.Condition: During fiscal year 2022, the State Opioid Response program was required to submit 5 program performance reports to the grantor. A Department program specialist or project manager compiles the State Opioid Response program performance progress reports and a contract manager review and approves the reports. The approval of the performance progress reports for all five (5) reports tested under the State Opioid Response program was not documented. Department staff indicated that the approval process was verbal or through e-mails that were not retained, and we were unable to verify this process.Cause: The Department did not consider that documentation to support the review and approval of these performance progress reports was necessary to ensuring accuracy and compliance with reporting requirements.Effect: We did not identify errors in the performance progress reports we reviewed. However, without documentation of appropriate internal controls, there is an increased risk of errors occurring and going undetected, or errors being present in reports we did not review. Further, the Department could submit the performance progress reports with incomplete or inaccurate information required by the grant agreement.Recommendation: We recommend that the Department design and implement procedures to ensure sufficient documentation is maintained that supports the review and approval of the performance progress reports.Management?s View: The Department agrees with the finding.Corrective Action: Beginning April 1, 2023, all required federal reports will include the following statement, which will be signed and dated electronically by the approving reviewer before the report is submitted:? I, _______________________, have reviewed and approved this report prior to submission.Name, titleA copy of the approved and signed report will be retained in DBH?s electronic grant funding records.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s view that the contract manager did complete reviews to ensure accuracy, but without documentation available to the auditors at the time we are completing auditing procedures it is difficult to verify if errors were detected, if they were properly corrected, and if the final version was then reviewed again to ensure accuracy. A clear documentation trail is critical to support accurate reporting and can also provide insight into improving the process so that errors do not continue to occur.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.

FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.

FINDING 2022-207The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Type of Finding: Significant DeficiencyAssistance Listing Title: Sport Fish Restoration; Wildlife Restoration and Basic Hunter EducationAssistance Listing Number: 15.605; 15.611Federal Award Number: F19AF00026; F19AF00093; F22AF00371; F14AF01014; F20AF11918; F22AF00372; F20AF11578; F21AF03374; F21AF03986; F21AF03986Program Year: January 1, 2019 ? December 31, 2021; January 1, 2019 ? December 31, 2021; January 1, 2022 ? December 31, 2024; August 1, 2014 ? June 30, 2022; July 1, 2020 ? June 30, 2021; January 1, 2022 ? December 31, 2024; July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023; July 1, 2021 ? June 30, 2022; July 1, 2021 ? June 30, 2022Federal Agency: Department of the InteriorCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR ?200.510(b), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502, and? Total amount provided to subrecipients from each federal programCondition: The Department completed a SEFA closing package to report federal grant expenditures. The amount reported as passed through to subrecipients was overstated by a total of $331,500. The Sport Fish Restoration Program (Assistance Listing Number 15.605) payments to subrecipients were overstated by $10,513, and the Wildlife Restoration Program (Assistance Listing Number 16.611) payments to subrecipients were overstated by $320,987.Cause: The Department made payments to entities who received subawards under the grants and also provided specific vendor services for the grants. The person compiling the SEFA closing package was new to that process and included all payments to the entities as payments to subrecipients, even though some of the payments were for vendor services and should not have been included. The SEFA closing package was reviewed for accuracy prior to being submitted to the Office of the State Controller, but this review did not detect the error.Effect: The Department?s SEFA closing package overstated the amount passed through to subrecipients by $331,500. The total expenditures for the grant programs were $7,196,361 in the Sport Fish Restoration Program and $15,479,486 in the Wildlife Restoration Program. Subrecipient payments make up a small portion of the overall grant expenditures comprising $31,539 in the Sport Fish Restoration Program (0.44 percent of the total) and $520,630 in the Wildlife Restoration Program (3.36 percent of the total). The effect is limited because the trivial materiality for the statewide SEFA is $1.9 million. The Department submitted a corrected SEFA closing package to correct the error.Recommendation: We recommend that the Department design and implement procedures to ensure amounts passed through to subrecipients are accurately reported on the SEFA closing package.Management?s View: The Department has reviewed its reporting of subrecipient expenditures on the State Fiscal Year 2022 Schedule of Expenditure of Federal Awards (?SEFA?) and agrees with the finding that an overstatement was made.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA. This corrective action plan will be implemented by the end of August 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-207The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Type of Finding: Significant DeficiencyAssistance Listing Title: Sport Fish Restoration; Wildlife Restoration and Basic Hunter EducationAssistance Listing Number: 15.605; 15.611Federal Award Number: F19AF00026; F19AF00093; F22AF00371; F14AF01014; F20AF11918; F22AF00372; F20AF11578; F21AF03374; F21AF03986; F21AF03986Program Year: January 1, 2019 ? December 31, 2021; January 1, 2019 ? December 31, 2021; January 1, 2022 ? December 31, 2024; August 1, 2014 ? June 30, 2022; July 1, 2020 ? June 30, 2021; January 1, 2022 ? December 31, 2024; July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023; July 1, 2021 ? June 30, 2022; July 1, 2021 ? June 30, 2022Federal Agency: Department of the InteriorCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR ?200.510(b), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502, and? Total amount provided to subrecipients from each federal programCondition: The Department completed a SEFA closing package to report federal grant expenditures. The amount reported as passed through to subrecipients was overstated by a total of $331,500. The Sport Fish Restoration Program (Assistance Listing Number 15.605) payments to subrecipients were overstated by $10,513, and the Wildlife Restoration Program (Assistance Listing Number 16.611) payments to subrecipients were overstated by $320,987.Cause: The Department made payments to entities who received subawards under the grants and also provided specific vendor services for the grants. The person compiling the SEFA closing package was new to that process and included all payments to the entities as payments to subrecipients, even though some of the payments were for vendor services and should not have been included. The SEFA closing package was reviewed for accuracy prior to being submitted to the Office of the State Controller, but this review did not detect the error.Effect: The Department?s SEFA closing package overstated the amount passed through to subrecipients by $331,500. The total expenditures for the grant programs were $7,196,361 in the Sport Fish Restoration Program and $15,479,486 in the Wildlife Restoration Program. Subrecipient payments make up a small portion of the overall grant expenditures comprising $31,539 in the Sport Fish Restoration Program (0.44 percent of the total) and $520,630 in the Wildlife Restoration Program (3.36 percent of the total). The effect is limited because the trivial materiality for the statewide SEFA is $1.9 million. The Department submitted a corrected SEFA closing package to correct the error.Recommendation: We recommend that the Department design and implement procedures to ensure amounts passed through to subrecipients are accurately reported on the SEFA closing package.Management?s View: The Department has reviewed its reporting of subrecipient expenditures on the State Fiscal Year 2022 Schedule of Expenditure of Federal Awards (?SEFA?) and agrees with the finding that an overstatement was made.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA. This corrective action plan will be implemented by the end of August 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-203Errors in the elimination process for federal grants between State agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 provided to subrecipients.Type of Finding: Significant Deficiency, SEFA MisstatementAssistance Listing Title: State and Local Fiscal Recovery Fund; Gaining Early Awareness and Readiness for Undergraduate ProgramsAssistance Listing Number: 21.027; 84.334SFederal Award Number: 20-1982-0-1-806; PS334S110016Program Year: March 3, 2021 - December 31, 2024; September 26, 2011 - September 25, 2018Federal Agency: Department of Treasury; Department of EducationCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions. It provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programCondition: The SEFA submitted for audit purposes included misstatements for Direct Awards and Amounts Provided to Subrecipients for Assistance Listing (AL) Number 21.027 (Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)) and 84.334S (Gaining Early Awareness and Readiness for Undergraduate Programs (GEARUP)). We noted the following errors:? Amounts for AL Number 21.027 were overstated by $12,534,055 for Direct Award Expenditures and by $12,171,845 for Amounts Provided to Subrecipients? Amounts for AL Number 84.334S were understated by $2,122,873 for Direct Expenditures and by $2,106,517 for Amounts Provided to SubrecipientsCause: Each year, State agencies report the total of federal awards expended on a closing package. The Office uses these closing packages to compile the SEFA. Federal funds received by one State agency and then passed on to another State agency get reported on both State agencies? SEFA closing package. The Office completes eliminations to avoid double counting expenditures for the same federal program. The Office?s review procedures over this process did not detect or prevent the duplicate expenditures for AL Number 21.027 and did not prevent the erroneous elimination of actual expenditures for AL Number 84.334S.Effect: The SEFA submitted for audit contained misstatements; however, these errors have been corrected.Recommendation: We recommend that the Office design and implement procedures to ensure amounts are properly reported and proper adjustments are made when federal funds are shared between State agencies.Management?s View: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-205An expenditure was made by the Department for unallowable activities from the Elementary and Secondary School Emergency Relief (ESSER) program.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Education Stabilization Fund - ARPA ESSER IIIAssistance Listing Number: 84.425UFederal Award Number: S425U210043Program Year: March 24, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Activities allowed or unallowedQuestioned Costs: Known: $2,270.65; Likely: $71,576Criteria: The Department awards and passes ESSER funds to school districts or local educational agencies (LEAs) in the State. The LEAs may use ESSER funds for a wide range of activities to address needs arising from the coronavirus pandemic. The ESSER funding is made available by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and the American Rescue Plan (ARP) Act. The CARES Act (Section 18003 (d)) provides a broad list of LEA allowable activities. The CRRSA Act (Section 313(3)) includes additional LEA allowable uses of funds, in particular addressing learning loss; preparing schools for reopening; and testing, repairing, and upgrading projects to improve air quality in school buildings. The ARP Act (Section 2001(e)) further expands LEA allowable uses of funds to include providing mental health support, developing strategies, and implementing public health protocols on reopening and operating schools to effectively maintain the health and safety of students, educators, and staff.Condition: During our review of ESSER grant expenditures for allowable activities and costs, we selected a sample of 60 transactions to evaluate for compliance, substantive accuracy, and adequately designed and applied internal controls. We noted one transaction for $12,374.83 that included $2,270.65 for staff lunches, which are unallowable as a cost paid for by this grant.Cause: A subrecipient of the Department requested reimbursement from the ESSER grant in June 2022 for employee salaries and benefits, supplies, materials, and staff meals. Staff meals are unallowable to the ESSER grant. This unallowable activity was not identified during the Department?s review of the transaction. Department personnel reviewing and approving the reimbursement request believed that, based upon the wording in the request, the transaction was for different purposes and allowable under the ESSER grant. However, further review and inquiring to the LEA after the audit exception was identified supported that the expenditure was not allowed.Effect: The Department reimbursed unallowed costs of $2,271 which results in projected questioned costs of $71,576 for the ESSER program.Recommendation: We recommend that the Department strengthen control procedures to ensure all expenditures are allowable prior to approving reimbursement to LEAs.Management?s View: The Department agrees with this finding.Corrective Action: When the Elementary and Secondary School Emergency Relief Funds {ESSER) were first awarded, it was not required that districts attach any documentation to their Grant Reimbursement Application {GRA) requests. Federal Programs will start requiring that all requests coming in through the GRA system have supporting documentation attached as of July 1, 2023, which is the beginning of our next fiscal cycle. We will announce this new procedure through emails and during our state-wide Consolidated Federal and State Grant Application training in April and May 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We agree with the Department that it is important to provide the additional guidance received from the federal grantors to the subrecipients, we want to emphasize that it is the Department?s responsibility to ensure that only allowable costs are reimbursed to the LEAs, and to implement appropriate internal control activities, including adequate supporting documentation, to ensure compliance with this requirement.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.

FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-208State Opioid Response program performance progress reports did not have documentation to support completion of a review for accuracy and compliance prior to submission.Type of Finding: Material WeaknessAssistance Listing Title: Opioid STRAssistance Listing Number: 93.788Federal Award Number: H79TI083282; H79TI081727Program Year: September 30, 2020 ? September 29, 2023; September 30, 2018 ? September 29, 2021Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.Condition: During fiscal year 2022, the State Opioid Response program was required to submit 5 program performance reports to the grantor. A Department program specialist or project manager compiles the State Opioid Response program performance progress reports and a contract manager review and approves the reports. The approval of the performance progress reports for all five (5) reports tested under the State Opioid Response program was not documented. Department staff indicated that the approval process was verbal or through e-mails that were not retained, and we were unable to verify this process.Cause: The Department did not consider that documentation to support the review and approval of these performance progress reports was necessary to ensuring accuracy and compliance with reporting requirements.Effect: We did not identify errors in the performance progress reports we reviewed. However, without documentation of appropriate internal controls, there is an increased risk of errors occurring and going undetected, or errors being present in reports we did not review. Further, the Department could submit the performance progress reports with incomplete or inaccurate information required by the grant agreement.Recommendation: We recommend that the Department design and implement procedures to ensure sufficient documentation is maintained that supports the review and approval of the performance progress reports.Management?s View: The Department agrees with the finding.Corrective Action: Beginning April 1, 2023, all required federal reports will include the following statement, which will be signed and dated electronically by the approving reviewer before the report is submitted:? I, _______________________, have reviewed and approved this report prior to submission.Name, titleA copy of the approved and signed report will be retained in DBH?s electronic grant funding records.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s view that the contract manager did complete reviews to ensure accuracy, but without documentation available to the auditors at the time we are completing auditing procedures it is difficult to verify if errors were detected, if they were properly corrected, and if the final version was then reviewed again to ensure accuracy. A clear documentation trail is critical to support accurate reporting and can also provide insight into improving the process so that errors do not continue to occur.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.

FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.

FINDING 2022-204COVID-19 funds in the amount of $196,247,971 were not properly identified on the statewide Schedule of Expenditures of Federal Awards (SEFA), as required.Type of Finding: Noncompliance, Material Weakness, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Grants to States for Construction of State Home Facilities; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control Grants; Disaster Grants ? Public Assistance (Presidentially Declared Disasters)Assistance Listing Number: 10.551; 10.557; 10.561; 64.005; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977; 97.036Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; FAI 16-012; FAI 16-013; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171; 4534DRIP00000001Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; May 8, 2021 ? June 30, 2022; June 28, 2021 ? June 30, 2022; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023; May 8, 2020 ? June 30, 2022Federal Agency: Department of Agriculture; Department of Veterans Affairs; Department of Education; Health and Human Services; Department of Homeland SecurityCompliance Requirement: Code of Federal Regulations (CRF) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include risk assessment, control activities, and information and communication. Risk assessment is the identification and analysis of various risks entities face because of changing economic, industry, regulatory, and operating conditions, and provides a basis to develop appropriate responses to manage those risks. Control activities are policies and procedures that help ensure management directives are carried out and risks are mitigated. Verifications, approvals, reconciliations, authorizations, and segregation of duties are all control activities that support this objective. Information and communication relate to obtaining quality information and effective internal and external communication of that information to achieve management objectives.Management objectives should include the preparation and fair presentation of the SEFA in relation to the basic financial statements as a whole and in compliance with requirements contained in the U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) (2 CFR ?200.510(b)), which states it must include:? Total federal awards expended as determined in accordance with 2 CFR ?200.502? Total amount provided to subrecipients from each federal programAdditionally, the Office of Management and Budget (OMB) Memorandum M-20-26 instructed recipients and subrecipients to separately identify the COVID-19 Emergency Acts expenditures on the SEFA.Condition: Several assistance listings (AL) were not properly identified as COVID-19 funds on the SEFA submitted for audit. The following items were identified by the auditors and communicated to management during the audit process:? Supplemental Nutrition Assistance Program (AL Number 10.551) $38,370,588? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (AL Number 93.391) $3,387,573? Special Education - Grants for Infants and Families (AL Number 84.181) $265,777? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL Number 93.497) $183,807? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (AL Number 10.557) $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL Number 10.561) $354,983? Community-Based Child Abuse Prevention Grants (AL Number 93.590) $156,539? Block Grants for Community Mental Health Services (AL Number 93.958) $389,232? Sexually Transmitted Diseases (STD) Prevention and Control Grants (AL Number 93.977) $156,712? State Veterans Home Construction (AL Number 64.005) $1,513,996? Education Stabilization Fund - Emergency Assistance for Non-Public Schools (AL Number 84.425R) $3,145,463? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (AL Number 97.036) $146,776,143Cause: The Office has not developed procedures to ensure amounts reported by State agencies on closing packages properly identifies all funds related to COVID-19. The Office relies on State agencies to self-report federal expenditures, programs, and identify if these programs are related to COVID-19 funding through the closing package process. Current procedures do not include verifying that the COVID-19 designation is appropriately included.Additionally, review procedures did not identify an error that occurred while compiling the SEFA that did not include the COVID-19 designation for AL Number 84.425R. Internal reviews did not identify this error as this information was correctly included on the agency closing package.Effect: The SEFA submitted for audit did not properly identify $196,247,971 as COVID-19 funds on the SEFA; however, these errors have been corrected.Recommendation: We recommend that the Office implement procedures and controls to ensure funds related to the COVID-19 pandemic are properly identified on the SEFA.Management?s View: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Auditor?s Concluding Remarks: We thank the Office for its cooperation and assistance throughout the audit.