2022-002 Preparation of Schedule of Expenditures and Federal Awards (?SEFA?) and timelysubmission to Federal Clearing HouseSignificant deficiency in internal control over complianceFederal Program(s) ? All programsFederal Award Year ? June 30, 2022Criteria:2 CFR 200.302(b)(1) states that the nonfederal entity must identify in its accounts all federal awardsreceived and expended, as well as the federal programs under which they were received. Federalprogram and award identification must include, as applicable, the assistance listing title and number,the federal award identification number and year, the name of the federal agency, and the name of thepass-through entity, if any. This information enables the auditee to reconcile amounts presented in thefinancial statements to related amounts in the schedule of expenditures of federal awards. Managementis responsible for the preparation of the SEFA and timely submission of the audited package to theFederal Clearing House.Condition/context:GRYC maintains grant agreements with various government funding pass-through entities. WhileGRYC may not always be subject to the Uniform Guidance report due to not meeting the fundingthreshold, in fiscal year 2022, GRYC exceeded the annual minimal reporting requirement of $750,000.GRYC?s Uniform Guidance audit package was due for submission to the Federal Clearing House byMarch 31, 2023. However, GRYC was unable to effectively determine funding from federal programsthat were subject to Uniform Guidance and as a result, it did not submit the audited package to theFederal Clearing House on time.Cause:Prior to fiscal 2022, GRYC was not subject to the Uniform Guidance audit. In addition, all GRYC?sfederal funding is considered pass-through. As a result, GRYC was under the impression that none oftheir funding was considered federal funding subject to Uniform Guidance. Consequently, GRYC wasunable to sufficiently generate information on all federal funding received during fiscal year 2022 andas a result there was insufficient information available, which led to a delay in the audit process andfiling with the Federal Clearing House.Effect:GRYC maintains its grant documentation internally, however, GRYC did not consider several grantsas being subject to Uniform Guidance in preparation of their SEFA. GRYC did not meet the March31st, 2023, deadline for Federal Clearing House filing.Auditors? Recommendation:We recommend that GRYC develop policies and procedures to ensure compliance with the UniformGuidance reporting requirements that includes proper and timely preparation of SEFA and the timelyfiling of the audit package to the Federal Clearing House. We recommend frequent communicationbetween GRYC and pass-through agencies (funding sources) to help identify federal programs. Inaddition, we recommend GRYC provides more training to grant management staff to both enhancethe skill in identifying pass through programs and ensure the accuracy and completeness of the SEFA.The above recommendation can also be achieved by reviewing all contracts thoroughly and lookingfor provisions that state whether the contracts are federal or state funded. Similarly, if a contract hasan Assistance Listing Number (?ALN?), this could potentially indicate that such grant is federallyfunded. GRYC should also develop better procedures to track all revenues and expenditures over thenext fiscal year to determine whether it exceeded the $750,000 threshold and will be subject to anUniform Guidance audit.Managements Response:GRYC acknowledges and agrees with the finding and is in process of reviewing and analyzing allcontracts and amendments to ensure that the SEFA includes all federally awarded programs. GRYCwill start implementing this recommendation during the year ended June 30, 2023, and plans to filethe 2023 Uniform Guidance report timely.
2022-001 Grant Administration and Record KeepingSignificant deficiency in internal control over complianceFederal Program(s) ? 21st Century Community Learning Centers GrantFederal Agency(s) ? Department of EducationPass-Through Entity(ies) ? New York State Department of EducationFederal Assistance Listing Number(s) ? 84.287Pass-through Number(s) ? C403063/ C403077Federal Award Year ? June 30, 2022Criteria:In accordance with the grant agreement between GRYC and the New York State Education Department(NYSED) for the 21st Century Community Learning Centers Grant (?21st Century?), GRYC is requiredto administer and maintain records for the program, generate program reports, and meet annualreporting requirements as outlined in the grant agreement. Management is responsible for designing,implementing, and maintaining appropriate internal control over compliance. In conjunction with this,management needs to ensure that proper allocation methodologies are in place to ensure thatexpenditures are properly recorded to programs benefitted.Condition/context:During our audit, we detected certain deficiencies in internal control over compliance as describedbelow which are identified as a significant deficiency in internal control over compliance in an auditperformed under Uniform Guidance.Management currently allocates labor costs to the various program based upon managements estimate,utilizing internal factors such as service delivery, scheduling, job descriptions, etc. Federal guidelinesrequire employee allocations to various programs to be supported by either contemporaneous timerecords or appropriate time studies (2 weeks per quarter). While management?s estimate may be anaccurate reflection of how staff spent their time, without contemporaneous records completed by staff,management cannot be assured that the costs charged to each program are reflected of staff level ofeffort.Cause:NYSED requires that GRYC submit invoices quarterly of expenditures incurred during that periodand to date, which includes payroll expenses. GRYC relied on internal software and management?sestimates to determine how often an employee worked under said grant and how much costs shouldbe allocated.Due to the limitations of this calculation, GRYC was unable to generate sufficient payroll/ grantallocations data upon request during the audit, and as a result, there was insufficient informationavailable to audit the compliance with the program?s annual service level requirements.Effect:GRYC was unable to demonstrate that they effectively kept track of employees? payroll allocationamong grants with respect to reconciling to quarterly payroll reports. Although GRYC has beenunable to meet federal reporting guidelines, these requirements were waived by the funding sources.Auditors? Recommendation:We recommend that GRYC develops an internal schedule whereby employees? time allocationamongst various grant programs are tracked more closely. Federal guidelines require employees toallocate their time on a contemporaneous basis either throughout the year or through the use ofquarterly time study. GRYC should require such contemproneous reporting and develop procedureswhereby the percentage and salary allocation reconcile to the quarterly NYS-45?s filed with the State.GRYC should designate the responsibility to generate such reports to an employee to act as theprimary person to reconcile the two reports, and designate program leads to ensure the calculation isaccurate and consistent with time spent.Managements Response:GRYC acknowledges and agrees with the finding and is in the process of developing procedures toensure compliance with grant/contract provisions and will start implementing this recommendationfor the year ended June 30, 2024.
2022-002 Preparation of Schedule of Expenditures and Federal Awards (?SEFA?) and timelysubmission to Federal Clearing HouseSignificant deficiency in internal control over complianceFederal Program(s) ? All programsFederal Award Year ? June 30, 2022Criteria:2 CFR 200.302(b)(1) states that the nonfederal entity must identify in its accounts all federal awardsreceived and expended, as well as the federal programs under which they were received. Federalprogram and award identification must include, as applicable, the assistance listing title and number,the federal award identification number and year, the name of the federal agency, and the name of thepass-through entity, if any. This information enables the auditee to reconcile amounts presented in thefinancial statements to related amounts in the schedule of expenditures of federal awards. Managementis responsible for the preparation of the SEFA and timely submission of the audited package to theFederal Clearing House.Condition/context:GRYC maintains grant agreements with various government funding pass-through entities. WhileGRYC may not always be subject to the Uniform Guidance report due to not meeting the fundingthreshold, in fiscal year 2022, GRYC exceeded the annual minimal reporting requirement of $750,000.GRYC?s Uniform Guidance audit package was due for submission to the Federal Clearing House byMarch 31, 2023. However, GRYC was unable to effectively determine funding from federal programsthat were subject to Uniform Guidance and as a result, it did not submit the audited package to theFederal Clearing House on time.Cause:Prior to fiscal 2022, GRYC was not subject to the Uniform Guidance audit. In addition, all GRYC?sfederal funding is considered pass-through. As a result, GRYC was under the impression that none oftheir funding was considered federal funding subject to Uniform Guidance. Consequently, GRYC wasunable to sufficiently generate information on all federal funding received during fiscal year 2022 andas a result there was insufficient information available, which led to a delay in the audit process andfiling with the Federal Clearing House.Effect:GRYC maintains its grant documentation internally, however, GRYC did not consider several grantsas being subject to Uniform Guidance in preparation of their SEFA. GRYC did not meet the March31st, 2023, deadline for Federal Clearing House filing.Auditors? Recommendation:We recommend that GRYC develop policies and procedures to ensure compliance with the UniformGuidance reporting requirements that includes proper and timely preparation of SEFA and the timelyfiling of the audit package to the Federal Clearing House. We recommend frequent communicationbetween GRYC and pass-through agencies (funding sources) to help identify federal programs. Inaddition, we recommend GRYC provides more training to grant management staff to both enhancethe skill in identifying pass through programs and ensure the accuracy and completeness of the SEFA.The above recommendation can also be achieved by reviewing all contracts thoroughly and lookingfor provisions that state whether the contracts are federal or state funded. Similarly, if a contract hasan Assistance Listing Number (?ALN?), this could potentially indicate that such grant is federallyfunded. GRYC should also develop better procedures to track all revenues and expenditures over thenext fiscal year to determine whether it exceeded the $750,000 threshold and will be subject to anUniform Guidance audit.Managements Response:GRYC acknowledges and agrees with the finding and is in process of reviewing and analyzing allcontracts and amendments to ensure that the SEFA includes all federally awarded programs. GRYCwill start implementing this recommendation during the year ended June 30, 2023, and plans to filethe 2023 Uniform Guidance report timely.
2022-001 Grant Administration and Record KeepingSignificant deficiency in internal control over complianceFederal Program(s) ? 21st Century Community Learning Centers GrantFederal Agency(s) ? Department of EducationPass-Through Entity(ies) ? New York State Department of EducationFederal Assistance Listing Number(s) ? 84.287Pass-through Number(s) ? C403063/ C403077Federal Award Year ? June 30, 2022Criteria:In accordance with the grant agreement between GRYC and the New York State Education Department(NYSED) for the 21st Century Community Learning Centers Grant (?21st Century?), GRYC is requiredto administer and maintain records for the program, generate program reports, and meet annualreporting requirements as outlined in the grant agreement. Management is responsible for designing,implementing, and maintaining appropriate internal control over compliance. In conjunction with this,management needs to ensure that proper allocation methodologies are in place to ensure thatexpenditures are properly recorded to programs benefitted.Condition/context:During our audit, we detected certain deficiencies in internal control over compliance as describedbelow which are identified as a significant deficiency in internal control over compliance in an auditperformed under Uniform Guidance.Management currently allocates labor costs to the various program based upon managements estimate,utilizing internal factors such as service delivery, scheduling, job descriptions, etc. Federal guidelinesrequire employee allocations to various programs to be supported by either contemporaneous timerecords or appropriate time studies (2 weeks per quarter). While management?s estimate may be anaccurate reflection of how staff spent their time, without contemporaneous records completed by staff,management cannot be assured that the costs charged to each program are reflected of staff level ofeffort.Cause:NYSED requires that GRYC submit invoices quarterly of expenditures incurred during that periodand to date, which includes payroll expenses. GRYC relied on internal software and management?sestimates to determine how often an employee worked under said grant and how much costs shouldbe allocated.Due to the limitations of this calculation, GRYC was unable to generate sufficient payroll/ grantallocations data upon request during the audit, and as a result, there was insufficient informationavailable to audit the compliance with the program?s annual service level requirements.Effect:GRYC was unable to demonstrate that they effectively kept track of employees? payroll allocationamong grants with respect to reconciling to quarterly payroll reports. Although GRYC has beenunable to meet federal reporting guidelines, these requirements were waived by the funding sources.Auditors? Recommendation:We recommend that GRYC develops an internal schedule whereby employees? time allocationamongst various grant programs are tracked more closely. Federal guidelines require employees toallocate their time on a contemporaneous basis either throughout the year or through the use ofquarterly time study. GRYC should require such contemproneous reporting and develop procedureswhereby the percentage and salary allocation reconcile to the quarterly NYS-45?s filed with the State.GRYC should designate the responsibility to generate such reports to an employee to act as theprimary person to reconcile the two reports, and designate program leads to ensure the calculation isaccurate and consistent with time spent.Managements Response:GRYC acknowledges and agrees with the finding and is in the process of developing procedures toensure compliance with grant/contract provisions and will start implementing this recommendationfor the year ended June 30, 2024.