Food Commodity Shipments, Disbursements, and Inventory Not Tracked(Utah State Board of Education)Federal Agency: Department of EducationALN Numbers & Titles: 10.569 Emergency Food Assistance Program (Food Commodities)Federal Award Numbers: VariousQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Utah State Board of Education (USBE) does not have procedures to ensure that food commodity shipments, disbursements, and inventory balances, as reported by its subrecipient, are properly tracked, accounted for, and reconcile to federal records. As a result, 123,923 cases of food, with a $52,875 estimated value, could not be accounted for when our audit compared fiscal year 2022 shipment and disbursement records. These discrepancies were subsequently reconciled by USBE, therefore we are not questioning the associated costs.As the prime recipient for the Food Distribution Cluster, USBE is required to ?maintain records to document the receipt, disposal, and inventory of commodities received? (7 CFR 251.10). It is also required to ?establish and maintain effective internal control [procedures]?that provides reasonable assurance that the ? entity is managing [the program] in compliance with?terms and conditions of the federal award? (2 CFR 200.303). Without such procedures, USBE will be unable to accurately track food commodity shipments, and may be liable for untraceable shipments (7 CFR 250.19).Recommendation:We recommend that USBE establish procedures to ensure that food commodity shipments, disbursements, and inventory balances are properly tracked, accounted for, and reconcile to federal records.USBE?s Response:The USBE partially agrees with this finding.
FFATA Award Information Not Submitted for UOVC?s 2020 Award & Inaccurate Information Submitted for 5 of UOVC?s 2019 Subawards(Commission on Criminal and Juvenile Justice)Federal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2019-V2-GX-00632020-V2-GX-0015Questioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AUtah?s Office of Victims of Crime (UOVC) did not submit Federal Funding Accountability and Transparency Act (FFATA) information for 13 awards to 13 subrecipients, all related to the 2020 award. In addition, 5 of the 28 grant awards we reviewed were reported in FSRS but the amounts reported did not agree to the subaward letters, with differences ranging from $34 to $405,000. We reviewed USASpending.gov and noted that no subrecipient award information for the 2020-V2-GX-0015 award had been submitted as of August 22, 2022 (the time of our audit). The following table summarizes the discrepancies for the transactions and subawards tested:(See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires entities to ?establish and maintain effective internal controls [procedures]?that provide reasonable assurance that the ? entity is managing [federal program] in compliance with? terms and conditions of the federal award.? This control does not exist because managers both relied on an external control at the federal level to flag reporting issues and misunderstood reporting deadlines. Lack of FFATA reporting internal controls at UOVC results in noncompliance with grant requirements and reduces the transparency desired by the federal government.Recommendation:We recommend that UOVC implement controls over FFATA reporting and enter final award information rather than preliminary award information to ensure timely submission of accurate information.UOVC?s Response:UOVC Agrees.
Three SF-425 Quarterly Reports Not Reviewed for Accuracy Prior to SubmissionFederal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2018-V2-GX-00512019-V2-GX-00632020-V2-GX-0015Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2020-027, 2019-017, 2018-025For the 3 SF-425 reports selected, UOVC did not perform an independent review prior to submission, resulting in inaccurate amounts being reported in the reports. In UOVC?s efforts to improve its internal controls over the Crime Victim Assistance (CVA) grant, it received approval to fund a new financial manager position to act as a key control over CVA grant management. Because UOVC did not fill this position until June 2022, internal controls during fiscal year 2022 were insufficient in preventing or detecting and correcting errors in these reports. UOVC?s new financial manager should perform an independent review of SF-425 reports and ensure the information reported agrees to the underlying accounting records. Without such reviews, SF-425 reports may continue to include inaccurate information and would lead to noncompliance with reporting requirements.Recommendation:We recommend UOVC?s independent review verify the accuracy of the SF-425 reports.UOVC?s Response:UOVC Agrees.
Initial Eligibility Determination Not Documented for 3 SubrecipientsFederal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2018-V2-GX-00512019-V2-GX-00632020-V2-GX-0015Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AUOVC could not provide adequate documentation evidencing its controls over the determination of 3 subrecipients? eligibility. Standard UOVC procedures include the intake grant analyst?s review of a grant application, evidenced by the completion of an eligibility checklist. Subject matter experts then grade a subrecipient?s grant application based on the checklist. For 10 of the 13 subrecipients reviewed, the checklists were completed. For 3 of the 13 (23%), they were not. We did not question payments to the 3 subrecipients as we were able to determine they were eligible entities. Inconsistent application of standard UOVC procedures may result in incorrect eligibility determinations of subrecipients.Recommendation:We recommend UOVC comply with its standard procedures for subrecipient eligibility determination.UOVC?s Response:UOVC Agrees.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Annual Medicaid Eligibility Reviews Not Completed(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS and DWS did not complete the annual Medicaid eligibility reviews for 3 of 60 cases sampled. In addition, it did not complete an asset verification for one of these 3 cases. As required by 42 CFR 435.916, states must:? renew MAGI-based determinations of eligibility once every 12 months and no more frequently;? renew non-MAGI based eligibility at least once every 12 months.Section 721-1.A.1.b.i of the Utah Medicaid Policy Manual requires that asset verifications be completed as part of these eligibility reviews. Question 10 of the COVID-19 Q&A within Medicaid Policy states that when an eligibility review is due during the emergency period, it should ?follow [the] normal review policy in section 721.? While DHHS did not complete these reviews because individuals could not be removed from programs during the public health emergency, individuals could have be moved to more appropriate programs if their income or household composition changes. The lack of regular reviews could result in Medicaid customers receiving coverage that does not match their needs and could also prolong individuals? ineligible participation in programs once the emergency period ends.Recommendation:We recommend that DHHS perform annual reviews and asset verifications in accordance with its policy.DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Department of Workforce Services (DWS) to whom we have delegated authority to perform eligibility determinations for Medicaid and CHIP and will ensure that DWS properly follows policy sections 721-1.A.1.b.i and COVID-19 Q & A question 10. DWS will train staff on proper use of the asset verification system, as well as remind staff on the review policy. DWS? Performance Review Team will also review a sample of cases to ensure compliance with these policies.DWS?s Response:We agree with the finding.
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Required Audits of MCO Encounter and Financial Data Not Conducted(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Department of Health and Human Services (DHHS) did not conduct or contract for independent periodic audits of Managed Care Organization (MCO) encounter and financial data and did not post audit results as required by 42 CFR Section 438.602(e) & (g). No independent audits of the necessary data have been performed or contracted to date. DHHS staff believed audits of the Medical Loss Ratio (MLR) satisfied federal requirements. However, the MLR audits do not attest to the ?accuracy, truthfulness, and completeness? of an MCO?s encounter and financial data. Unaudited encounter data not available to the public for review reduces the transparency in the Medicaid Program and causes noncompliance with federal requirements.Recommendation:We recommend DHHS either conduct or contract for independent periodic audits of MCO data and post the audit results in accordance with 42 CFR 438.602(3) & (g).DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Utah OIG to audit these encounters and/or conduct these periodic audits with Medicaid staff. The results will be posted on the Utah Medicaid website.
Medical Loss Ratio Report Lacked Two Required Elements(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 1 of 2 Medical Loss Ratio (MLR) reports we reviewed, DHHS could not provide evidence that it had performed in a timely manner a review of the MLR report. Additionally, the MLR report did not contain two key reporting items. Specifically, the Pre-Paid Inpatient Health Plan (PIHP)?s MLR report was 1) missing the methodologies for the allocation of expenditures; and, 2) a signed attestation of accuracy. 42 CFR sections 438.8(k) and 438.8(n) require that ?the State must ensure that each. . . PIHP. . . submits a report with the data elements specified.? 2 CFR 300.303 also requires non-federal entities to ?establish and maintain effective internal control over the Federal award that provides reasonable assurance.? Inadequate reviews of MLR Reports may result in improper methodologies and inaccuracies in the MLR calculations to remain undetected.Recommendation:We recommend DHHS enforce the established internal controls over MLR reporting, and educate DHHS staff and Managed Care Plans of the Federal reporting requirements.DHHS?s Response:The Department concurs with this recommendation. The Department will ensure that all required elements of the MLR are received by having DHHS staff review elements of the MLR to ensure they are complete.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
Annual Medicaid Eligibility Reviews Not Completed(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS and DWS did not complete the annual Medicaid eligibility reviews for 3 of 60 cases sampled. In addition, it did not complete an asset verification for one of these 3 cases. As required by 42 CFR 435.916, states must:? renew MAGI-based determinations of eligibility once every 12 months and no more frequently;? renew non-MAGI based eligibility at least once every 12 months.Section 721-1.A.1.b.i of the Utah Medicaid Policy Manual requires that asset verifications be completed as part of these eligibility reviews. Question 10 of the COVID-19 Q&A within Medicaid Policy states that when an eligibility review is due during the emergency period, it should ?follow [the] normal review policy in section 721.? While DHHS did not complete these reviews because individuals could not be removed from programs during the public health emergency, individuals could have be moved to more appropriate programs if their income or household composition changes. The lack of regular reviews could result in Medicaid customers receiving coverage that does not match their needs and could also prolong individuals? ineligible participation in programs once the emergency period ends.Recommendation:We recommend that DHHS perform annual reviews and asset verifications in accordance with its policy.DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Department of Workforce Services (DWS) to whom we have delegated authority to perform eligibility determinations for Medicaid and CHIP and will ensure that DWS properly follows policy sections 721-1.A.1.b.i and COVID-19 Q & A question 10. DWS will train staff on proper use of the asset verification system, as well as remind staff on the review policy. DWS? Performance Review Team will also review a sample of cases to ensure compliance with these policies.DWS?s Response:We agree with the finding.
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Required Audits of MCO Encounter and Financial Data Not Conducted(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Department of Health and Human Services (DHHS) did not conduct or contract for independent periodic audits of Managed Care Organization (MCO) encounter and financial data and did not post audit results as required by 42 CFR Section 438.602(e) & (g). No independent audits of the necessary data have been performed or contracted to date. DHHS staff believed audits of the Medical Loss Ratio (MLR) satisfied federal requirements. However, the MLR audits do not attest to the ?accuracy, truthfulness, and completeness? of an MCO?s encounter and financial data. Unaudited encounter data not available to the public for review reduces the transparency in the Medicaid Program and causes noncompliance with federal requirements.Recommendation:We recommend DHHS either conduct or contract for independent periodic audits of MCO data and post the audit results in accordance with 42 CFR 438.602(3) & (g).DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Utah OIG to audit these encounters and/or conduct these periodic audits with Medicaid staff. The results will be posted on the Utah Medicaid website.
Medical Loss Ratio Report Lacked Two Required Elements(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 1 of 2 Medical Loss Ratio (MLR) reports we reviewed, DHHS could not provide evidence that it had performed in a timely manner a review of the MLR report. Additionally, the MLR report did not contain two key reporting items. Specifically, the Pre-Paid Inpatient Health Plan (PIHP)?s MLR report was 1) missing the methodologies for the allocation of expenditures; and, 2) a signed attestation of accuracy. 42 CFR sections 438.8(k) and 438.8(n) require that ?the State must ensure that each. . . PIHP. . . submits a report with the data elements specified.? 2 CFR 300.303 also requires non-federal entities to ?establish and maintain effective internal control over the Federal award that provides reasonable assurance.? Inadequate reviews of MLR Reports may result in improper methodologies and inaccuracies in the MLR calculations to remain undetected.Recommendation:We recommend DHHS enforce the established internal controls over MLR reporting, and educate DHHS staff and Managed Care Plans of the Federal reporting requirements.DHHS?s Response:The Department concurs with this recommendation. The Department will ensure that all required elements of the MLR are received by having DHHS staff review elements of the MLR to ensure they are complete.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DHHS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DHHS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Working Capital Reserves in Excess of Federal Guidelines(Department of Government Operations)Federal Agency: VariousAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: UndeterminablePass-through Entity: NonePrior Year Single Audit Report Finding Number: 2021-025,2020-036; 2019-023; 2018-033; 2017-021; 2016-037; 2015-048; 2014-040; 2013-049; 2012-51; 2011-56As of June 30, 2022, four divisions within the Department of Government Operations (DGO) held working capital reserves in excess of federal guidelines of at least the amount that follows: (see the Schedule of Findings and Questioned Costs for the table)The following divisions do not have excess reserves at the internal service fund level, however, the federal oversight agency requires them to be assessed at the service area level, which resulted in excess reserves as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200, Appendix V, paragraph G.2, generally allows a working capital reserve as part of retained earnings of up to 60 days? cash expenses for normal operating purposes in each internal service fund. For DTS, the federal oversight agency only allows 45 days. The excess reserves were due to the inherent difficulty of accurately estimating expenses when setting rates. Excess reserves could result in a federal liability since federal programs share an interest in the reserves.Recommendation:Depending on the business requirements, we recommend each division within DGO reduce excess working capital reserves within each of the respective funds or service areas or obtain a waiver for an increase in the number of days of working capital allowed to comply with federal guidelines.DGO?s Response:Division of Purchasing and General ServicesCooperative Contract Management ? Public entities in Utah rely on the Division of Purchasing and General Services (State Purchasing) to maintain the cooperative contract program to help with public procurement in Utah. The usage of state cooperative contracts by public entities increased dramatically this past year resulting in a corresponding increase in the collection of administrative fees. State Purchasing still continues to decrease the administrative fees on state cooperative contracts as each contract expires and is rebid. This is a slow process since State Purchasing has nearly 1,200 cooperative contracts that expire only every five years. Although State Purchasing is allowed under law to collect up to a 1.0% administrative fee on each cooperative contract, currently the average administrative fee is 0.38%. State Purchasing has also requested the Utah Legislature to appropriate out a portion of the excess reserves in this fund in fiscal year 2023. The calculation for the refund of the federal portion of this transfer out will be submitted to Cost Allocation Services for review and approval when this transfer is complete.Federal and State Surplus Property - Due to the completion of the new Utah State Prison, Surplus Property anticipates relocating by the end of calendar year 2023. At that time, Federal and State Surplus will need to use their working capital reserve funds for the costs of moving to and furnishing their new location. These additional expenses should eliminate these excess reserves by December 2023.Purchasing Cards ? The Division of Finance (State Finance) is in the process of implementing a new travel and expense reporting system for all State agencies to simplify travel approvals, travel reimbursements, and reduce the administrative burden for the purchasing card (p-card) expense reports on State agency personnel. To cover system implementation costs, State Finance elected not to distribute the rebates received from U.S. Bank related to State agency p-card spending for calendar years 2021 and 2022. Rebates were still passed through to participating entities external to the primary government. The anticipated completion date for the system is the end of calendar year 2023. State Finance will review annually the costs of the system, develop a cost allocation strategy between the Travel and P-Card programs, adjust travel rates to cover the travel program?s ongoing costs, and distribute any remaining p-card rebates to State agencies respective to their spend. This effort will reduce and/or eliminate excess federal reserves by the end of fiscal year 2024.Division of Risk ManagementWorkers? Compensation Fund & Property? We requested approval in the current legislative session to transfer $2,000,000 out of the Workers Compensation Fund and into the Property Fund. We will submit the calculation for the refund of the federal portion of this transfer to Cost Allocation Services for their review and approval when this transfer is completed. Additionally, in FY 2023, the premiums charged for workers compensation have been reduced 26% from $0.61 per $100 to $0.45 per $100. The property commercial insurance market and the Property Fund are experiencing enormous year-over-year premium increases. We have seen a doubling of premiums in the last five years, from $14,000,000 to $28,000,000. Additionally, the budget process requires that we project funding 1-2 years in advance before we can enact rate increases to pay the excess insurance premiums that are due each fiscal year. As such, we deem it important to maintain a retained earnings balance in the Property Fund to be able to sustain the Fund's ability to pay for increasing premiums.Division of Technology ServicesPrint Services ? DTS currently projects Print Services retained earnings will decrease by $181 thousand in fiscal year 2023. The Print Services rate was set lower than the cost to provide this service in fiscal year 2024. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Print Services into compliance with federal excess reserve guidelines by the end of fiscal year 2024.Communication Services - The fiscal year 2024 rate was set to under recover the cost of providing this service by an additional $425 thousand. Because the reductions to retained earnings were smaller than expected in fiscal year 2022 and are projected to be smaller than expected in fiscal year 2023, DTS will need an additional year to address this excess. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Communication Services into compliance with federal excess reserve guidelines by the end of fiscal year 2025.Network Services - DTS anticipates significant expenses to this product in fiscal year 2023 as DTS upgrades the aging network infrastructure and as the demand for network services continues to increase (e.g. Agencies are asking for increased bandwidth). Upgrades to the infrastructure have been more complex than originally estimated, which has delayed the majority of this expense to fiscal year 2023. DTS projects the Network Services retained earnings will decrease by nearly $1 million in fiscal year 2023. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Network Services into compliance with federal excess reserve guidelines by the end of fiscal year 2023.Mainframe Services - This product will be coming to an end by fiscal year 2024. As the product ends, DTS will issue a rebate to reduce retained earnings to the agencies using the system. DTS plans to issue a credit in fiscal year 2023 which will bring Mainframe Services into compliance.Division of Human Resource ManagementHuman Resources Core Services - The Division of Human Resource Management (DHRM) projects DHRM Core Services expenses to increase in fiscal year 2023 and future years. The DHRM Core Services excess reserves was the result of an error correction. In an effort to decrease these excess reserves, DHRM has not requested a rate increase for DHRM Core Services, though we do anticipate costs to increase. We will continue to annually review and adjust the DHRM Core Services rate and, if necessary, issue refunds or rebates to ensure DHRM Core Services is in compliance with federal excess reserve guidelines by the end of fiscal year 2024.
Working Capital Reserves in Excess of Federal Guidelines(Public Employees Health Plan)Federal Agency: VariousAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: UndeterminablePass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-026; 2020-039; 2019-026; 2018-036; 2017-023; 2016-039; 2015-050; 2014-042; 2013-050; 2012 12-53; 2011 11-58As of June 30, 2022, the Public Employees Health Program (PEHP) held working capital reserves in excess of federal guidelines as follows below. (See Schedule of Findings and Questioned Costs for the table)2 CFR part 200, Appendix V, paragraph G.2, generally allows a working capital reserve as part of retained earnings of up to 60 days? cash expenses for normal operating purposes. The inherent difficulty of accurately estimating expenses led to excess reserves. Excess reserves could result in a federal liability since federal programs share an interest in the reserves. Recommendation:Depending on the business requirements, we recommend PEHP:1. Reduce excess working capital reserves, or2. Obtain a waiver from the federal cost negotiator allowing an increase in the number of days of working capital allowed to comply with federal guidelines.PEHP?s Response:Long-term DisabilityPEHP operates as a fully functioning third party-administrator for Long-term Disability benefits for the state of Utah and other public entities in Utah. Consequently, the reserves that PEHP holds and administers for the state of Utah do not relate to the payment of premium but the payment of ongoing, multi-year benefits for plan participants. These are vested benefits that PEHP would be required to pay on behalf the state for plan recipients, even if the program was discontinued and premiums were no longer collected. Because of this, PEHP will return excess premiums identified by our outside actuary while also seeking to obtain a waiver from the federal cost negotiator during 2023 to allow an increase in the number of days of working capital in compliance with federal guidelines.Medicare SupplementPEHP operates as a fully functioning third party-administrator for Medicare Supplement and Part D benefits for the state of Utah and other public entities in Utah. Consequently, the reserves that PEHP holds and administers for the state of Utah do not relate to the payment of premium but the payment of ongoing benefits for plan participants. During 2023, PEHP will seek to obtain a waiver from the federal cost negotiator to allow an increase in the number of days of working capital in compliance with federal guidelines on three grounds. First, the volatile nature of Part D pharmacy claims. Second, the relatively small dollar amount associated with Medicare premiums that can create a higher level of potential volatility. Third, the relatively small number of members covered by PEHP?s Medicare products that can also create a higher level of potential volatility.
Food Commodity Shipments, Disbursements, and Inventory Not Tracked(Utah State Board of Education)Federal Agency: Department of EducationALN Numbers & Titles: 10.569 Emergency Food Assistance Program (Food Commodities)Federal Award Numbers: VariousQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Utah State Board of Education (USBE) does not have procedures to ensure that food commodity shipments, disbursements, and inventory balances, as reported by its subrecipient, are properly tracked, accounted for, and reconcile to federal records. As a result, 123,923 cases of food, with a $52,875 estimated value, could not be accounted for when our audit compared fiscal year 2022 shipment and disbursement records. These discrepancies were subsequently reconciled by USBE, therefore we are not questioning the associated costs.As the prime recipient for the Food Distribution Cluster, USBE is required to ?maintain records to document the receipt, disposal, and inventory of commodities received? (7 CFR 251.10). It is also required to ?establish and maintain effective internal control [procedures]?that provides reasonable assurance that the ? entity is managing [the program] in compliance with?terms and conditions of the federal award? (2 CFR 200.303). Without such procedures, USBE will be unable to accurately track food commodity shipments, and may be liable for untraceable shipments (7 CFR 250.19).Recommendation:We recommend that USBE establish procedures to ensure that food commodity shipments, disbursements, and inventory balances are properly tracked, accounted for, and reconcile to federal records.USBE?s Response:The USBE partially agrees with this finding.
FFATA Award Information Not Submitted for UOVC?s 2020 Award & Inaccurate Information Submitted for 5 of UOVC?s 2019 Subawards(Commission on Criminal and Juvenile Justice)Federal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2019-V2-GX-00632020-V2-GX-0015Questioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AUtah?s Office of Victims of Crime (UOVC) did not submit Federal Funding Accountability and Transparency Act (FFATA) information for 13 awards to 13 subrecipients, all related to the 2020 award. In addition, 5 of the 28 grant awards we reviewed were reported in FSRS but the amounts reported did not agree to the subaward letters, with differences ranging from $34 to $405,000. We reviewed USASpending.gov and noted that no subrecipient award information for the 2020-V2-GX-0015 award had been submitted as of August 22, 2022 (the time of our audit). The following table summarizes the discrepancies for the transactions and subawards tested:(See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires entities to ?establish and maintain effective internal controls [procedures]?that provide reasonable assurance that the ? entity is managing [federal program] in compliance with? terms and conditions of the federal award.? This control does not exist because managers both relied on an external control at the federal level to flag reporting issues and misunderstood reporting deadlines. Lack of FFATA reporting internal controls at UOVC results in noncompliance with grant requirements and reduces the transparency desired by the federal government.Recommendation:We recommend that UOVC implement controls over FFATA reporting and enter final award information rather than preliminary award information to ensure timely submission of accurate information.UOVC?s Response:UOVC Agrees.
Three SF-425 Quarterly Reports Not Reviewed for Accuracy Prior to SubmissionFederal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2018-V2-GX-00512019-V2-GX-00632020-V2-GX-0015Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2020-027, 2019-017, 2018-025For the 3 SF-425 reports selected, UOVC did not perform an independent review prior to submission, resulting in inaccurate amounts being reported in the reports. In UOVC?s efforts to improve its internal controls over the Crime Victim Assistance (CVA) grant, it received approval to fund a new financial manager position to act as a key control over CVA grant management. Because UOVC did not fill this position until June 2022, internal controls during fiscal year 2022 were insufficient in preventing or detecting and correcting errors in these reports. UOVC?s new financial manager should perform an independent review of SF-425 reports and ensure the information reported agrees to the underlying accounting records. Without such reviews, SF-425 reports may continue to include inaccurate information and would lead to noncompliance with reporting requirements.Recommendation:We recommend UOVC?s independent review verify the accuracy of the SF-425 reports.UOVC?s Response:UOVC Agrees.
Initial Eligibility Determination Not Documented for 3 SubrecipientsFederal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2018-V2-GX-00512019-V2-GX-00632020-V2-GX-0015Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AUOVC could not provide adequate documentation evidencing its controls over the determination of 3 subrecipients? eligibility. Standard UOVC procedures include the intake grant analyst?s review of a grant application, evidenced by the completion of an eligibility checklist. Subject matter experts then grade a subrecipient?s grant application based on the checklist. For 10 of the 13 subrecipients reviewed, the checklists were completed. For 3 of the 13 (23%), they were not. We did not question payments to the 3 subrecipients as we were able to determine they were eligible entities. Inconsistent application of standard UOVC procedures may result in incorrect eligibility determinations of subrecipients.Recommendation:We recommend UOVC comply with its standard procedures for subrecipient eligibility determination.UOVC?s Response:UOVC Agrees.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Improper Spending and Monitoring of Coronavirus Relief Fund Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: $643,375Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-019Three of five Coronavirus Relief Fund (CRF) transactions tested for internal controls (60 percent) and three of 65 expenditures (4.6 percent) tested for compliance did not have adequate reviews to ensure the expenditures charged to CRF were in accordance with the Department of the Treasury (Treasury) guidelines. We have questioned costs of $643,375 for the following expenditures, which were not directly traceable in response to the public health emergency:? One transaction for the Thrive125 program celebrating Utah?s statehood in the amount of $271,334;? One transaction for an indirect allocation of limited liability and insurance in the amount of $4,524 (this was also originally included in the budget); and? A portion of one transaction for an IT contract payment totaling $367,517.Our sample totaled $47,280,705 and was taken from a population total of $108,519,500.As the prime recipient for the State of Utah, GOPB did not ensure the State?s CRF was spent in accordance with the Treasury guidance and FAQs. Treasury guidance stipulates the Fund may only be used to cover costs that 1) were necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19), 2) were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State, and 3) were incurred during the period that began on March 1, 2020 and ended on December 31, 2021.GOPB?s inadequate oversight of expenditures and state agency inexperience with federal compliance caused these unallowable expenditures and created an environment for federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve oversight and monitoring of expenditures, especially of state agencies with less federal program experience, to ensure internal control over and compliance with CRF grant requirements.GOPB?s Response:GOPB agrees that documentation and monitoring could be improved. Documentation of the three questioned costs were not adequate enough to allow auditors to determine eligibility under CRF guidance. Nevertheless, GOPB believes the questioned costs will be determined eligible if examined by the Department of the Treasury, based on published guidance regarding economic support in connection with COVID?19, expenses for technical assistance, and administrative costs.As it relates to the first questioned cost, the Thrive 125 program provided economic assistance grants to businesses and organizations impacted by COVID-19. Utah?s creative arts industry, particularly performing artists, were significantly impacted by COVID-19. As part of the program, the grant recipients were required to provide free performances for the community, which enabled marketing opportunities for artists. This grant program underwent a CRF eligibility review, including discussions with the Unified Command Finance Group.With respect to the second questioned cost, when the state recognized the purchase order for the state?s COVID-19 dashboard was structured to allow for broader usage at no additional cost, the state decided to pilot several other dashboards. The purpose and eligibility of this expense was reviewed by the COVID Finance Steering Committee before it was funded with CRF funding.As for the third questioned cost, based on the final CARES Act CRF rule, GOPB agrees agencies are not permitted to apply indirect cost formulas for liability insurance. However, upon further review, $1,312 of the questioned $4,524 was already adjusted to be charged to a non-CRF funding source before the close of the fiscal year. The remaining $3,212 was directly related to the personnel who charged eligible time to the CRF and not based on an indirect cost formula. GOPB believes this would be a direct cost similar to workers compensation that is charged to employees each pay period.
Underlying Accounting Data Does Not Support Coronavirus Relief Fund Quarterly Reports(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-020The methodology used by GOPB to prepare and submit CRF quarterly financial reports did not ensure the complete and accurate reporting of expenditures as reflected in FINET, the State?s accounting system. We selected the January 2022 and April 2022 report submissions to test key line items. We were unable to agree the following line items to FINET:January 2022 ReportManual adjustments made to the original data totaled $39.9 million.$10.96 million of the manual adjustments for small business bridge loans were reclassified as expenditures without the transaction occurring in FINET. Additionally, a significant portion of the loans should not have been reclassified as grants.April 2022 Report$5.4 million of expenditures less than data used in the preparation schedules.Manual adjustments made to the data totaled $65.4 million.While manual adjustments, corrections, and other changes (i.e., FEMA reimbursements) are not unexpected in reports, we considered the following in relation to GOPB?s report preparation:A reconciliation of the underlying accounting data and manual adjustments in the reports to the ?official record? of CRF expenditures in FINET has not occurred.Underlying accounting data was inconsistently coded from 2020 through 2022 but has not been reconciled to ensure all appropriate expenditures have been reported.Manual adjustments include significant amounts of expenditures reimbursed by FEMA that may have been charged to both programs without detection.FINET does not track obligations and as such, reported obligations are manually included for reporting. The reported total cumulative obligations in January of $933,976,723 and in April of $934,765,677 could not be tested because they were not properly documented.Treasury?s guidance indicates that the ?prime recipient?s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient?s accounting system.? Additionally, the Treasury Office of Inspector General?s (OIG) FAQs on reporting and recordkeeping describe the need to correct errors or modifications in a timely manner and to report actual obligations and expenditures rather than estimates.GOPB relied on state agencies to properly code expenditures and to have a proper understanding of the appropriate use of funds. The data in FINET, the ?official record,? and expenditures reported drastically differed due to these coding differences and required manual adjustments that were not properly documented. GOPB personnel did not prioritize the reconciliation of FINET expenditures and obligations to those reported because of other duties, time constraints, and priorities. In addition to the failure to properly code and track expenditures, an untimely reconciliation can lead GOPB to significantly misreport expenditures, misidentify errors, and miscalculate obligations of funds to be returned to Treasury.Recommendation:We recommend GOPB perform timely reconciliation of reported expenditures to actual reimbursements to ensure reports are supported by the underlying accounting data and to make corrections and other necessary modifications occur in a timely manner.GOPB?s Response:GOPB agrees with this finding. GOPB acknowledges that because of complexities in coding and tracking during fiscal years 2020 to 2022 and a ten day federal reporting deadline, not all reported expenditures were reconciled before quarterly reports were submitted. Between July 2022 and January 2023, GOPB made significant progress by compiling and reconciling a master CRF expenditure file. After the final reconciliation is completed, GOPB is confident every transaction reported to the Department of the Treasury, including adjustments for FEMA reimbursements and other recategorizations, will be reconciled with FINET data.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing Documentation for Emergency Rental Assistance Payments(Department of Workforce Services)Federal Agency: Department of TreasuryAssistance Listing Number and Title: 21.023 Emergency Rental Assistance ProgramFederal Award Number: N/AQuestioned Costs: $7,914Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-016Five of the 38 sampled payments (an error rate of 13.2%) for the Emergency Rental Assistance Program (ERA) did not have documentation supporting the payment or had ineligible costs associated with the recipient. Specifically,? Two applications contained utility payments that were paid for amounts higher than the utility bill,? One application did not include a management signed lease,? One application did not include a signed W-9 form and a management signed lease, and? An application did not include a written attestation from the applicant.The above errors did not meet the documentation and eligibility criteria established by section 501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and/or section 3201 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021).These errors occurred because the eligibility workers did not follow all of the Department of Workforce Services (DWS) ERA procedures and the DWS Processors? review of these applications did not identify and correct the errors. This resulted in errors of $7,914 of $80,671 in payments sampled from a population of $150,666,251.Subsequent to DWS?s initial eligibility determination and payment approval, DWS was able to obtain the missing supporting documentation for two of these sampled payments through requisition from the landlords, which total $7,824 of the errors above.Recommendation:We recommend that eligibility workers follow DWS ERA procedures and program processors review the applications for completeness and accuracy prior to disbursing ERA payments.DWS?s Response:We agree with the finding.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
GOPB Overestimated Calculation for Revenue Loss Due to the Pandemic(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor?s Office of Planning and Budget (GOPB) overstated its calculation for the State?s revenue loss experienced due to the Coronavirus pandemic for calendar year 2020 as follows: (See the Schedule of Findings and Questioned Costs for the Table)The Department of the Treasury (Treasury) issued its Interim and Final Rules (within the Federal Register) and related FAQs to guide governments in how to calculate the revenue losses experienced due to the pandemic. The Interim Rule instructs governments to identify ?general revenue? based largely on the Census Bureau?s definition and expands it to include or exclude certain revenue sources, which creates certain complexities and inconsistencies in the revenue loss calculation. After notification of the errors described above, GOPB revised its calendar year 2020 revenue loss calculation to $810,578,599. Differences between the auditor?s loss recalculation and GOPB?s revised amounts are a result of potential differing interpretations of Treasury?s revenue loss calculation guidance (e.g. hospital charges for providing patient services that may be covered by Medicaid or Medicare as a provider).GOPB calculated the revenue loss based solely on its personnel?s experience and understanding of revenue classification and did not account for the completeness, accuracy, and complexity of revenues and other financial information recorded by the State and the State?s institutions of higher education. Personnel in these areas who possessed the necessary understanding should have been involved in the calculation. Additionally, GOPB personnel charged with internal control responsibilities over the calculation did not possess the necessary expertise and knowledge to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s oversight in these matters could cause material noncompliance with State and Local Fiscal Recovery Fund (SLFRF) requirements. Because Treasury?s guidance allows for reclassification of the excess expenditures, we have not questioned these costs. However, funds budgeted/obligated for future expenditures may not be available and may need to be revised.Recommendations:We recommend the following:? Review and revise cumulative expenditures and obligations/budgets to date to ensure the State?s plan for using the SLFRF allotment complies with Treasury guidance;? Resolve with Treasury the treatment of certain revenues and determine the impact on the State?s revenue loss calculation;? Ensure future revenue loss calculations follow Treasury?s guidance by utilizing the expertise and knowledge of key financial reporting personnel within the State and its institutions of higher education; and? Ensure individuals with internal control responsibilities over the calculation(s) possess the necessary understanding to ensure compliance with Treasury?s Interim and Final Rules.GOPB?s Response:GOPB agrees with this finding. GOPB agrees that the original August 2021 revenue loss calculation of $1,154,152,123 was incorrect due to incomplete reporting of revenue at the time of the calculation. GOPB personnel utilized the best information available at the time to complete this calculation. As more information has become available over the past 18 months it has become clear that the calculation needs to be done again. The revenue loss calculation was based on a calendar year, rather than a fiscal year and there were no official financial reports that could be used to compile the calendar year 2020 revenue totals at the time of the original calculation. GOPB had to rely on a combination of revenue data from the state?s financial system, FINET, as well as summarized revenue data from the financial systems used by institutions of higher education. When the original revenue loss calculation was completed in August 2021, financial reports had not been released for fiscal year 2021, which made it difficult to validate the calendar year 2020 general revenue reported by the institutions of higher education.
Improper Controls and Monitoring of State and Local Fiscal Recovery Funds Activity(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $15Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AAs the prime recipient for the State of Utah, GOPB did not design and implement proper controls over allowable activities and costs.We identified 23 of 60 expenditures (38.3 percent failure rate) without proper internal controls to monitor compliance as shown below: (See Schedule of Findings and Questioned Costs for the table)We identified only one instance of noncompliance for a payroll expenditure of $15 from an expenditure sample of $9,794,539. We projected the error over an expenditure population of $147,219,149, resulting in $225 of projected questioned costs.According to the SLFRF Final Rule Federal Register, ?Recipients must establish rigorous oversight and internal controls processes to monitor compliance with any applicable requirements, including compliance by subrecipients.?GOPB and the Legislature centrally approved project plans and state agencies relied on that approval to ensure actual costs complied with the plan or SFLRF guidance. GOPB?s centralized project oversight and state agency reliance on GOPB?s approval of projects, combined with inexperience with federal compliance caused these unallowable expenditures. Poor internal control design could cause federal funds to be used for purposes not allowed.Recommendation:We recommend GOPB improve its oversight and monitoring of expenditures by working with agencies to establish internal controls that ensure expenditures charged to SLFRF projects comply with such requirements.GOPB?s Response:GOPB agrees with this finding. Prior to spending SLFR funds, agencies were required to document project eligibility and how expenditures would be coded in the state?s financial system, FINET. Agencies operating outside of FINET were required to provide similar coded expenditure data from their financial systems. GOPB maintains that agencies with extensive experience with federal funds, such as the Department of Health and Human Services, have adequate controls in place to ensure that only appropriate and eligible costs are charged to SLFRF accounting codes. Additionally, GOPB performs a quarterly review of all expenditures with SLFRF accounting codes before reporting these expenditures to the Treasury Department and authorizing the agency to book SLFRF revenue for those expenditures. While preparing the January 2023 report, GOPB added an additional step to have agencies review the quarter?s expenditures. Even with these processes and procedures in place, GOPB agrees that improvements can be made in the guidance, training, and follow-up with agencies managing SLFR funds, including checking for adequate controls that would catch errors charged to the grant.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Inadequate Monitoring of Child Care Health and Safety Inspections(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADWS contracts with the state?s Department of Health and Human Services (DHHS) to perform Child Care Health and Safety inspections, but does not adequately monitor the results of these inspections. DWS attended 2 of the 7,489 child care provider inspections performed by DHHS Child Care Licensing personnel during fiscal year 2022, but did not review any of the remaining inspections to know whether the inspection occurred or the results of those inspections. DWS relied heavily on the agreement with DHHS to perform these inspections with minimal monitoring of DHHS?s performance. These health and safety inspections are required by 45 CFR section 98.41 and address specific areas such as first aid and CPR, safe sleeping practices, administration of medication, and child care worker training in these areas. The lack of proper monitoring could result in child care providers not meeting federal health and safety requirements.Recommendation:We recommend that DWS increase its monitoring of the inspection results to ensure the child care providers are meeting the required health and safety requirements required by 45 CFR 98.41.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Annual Medicaid Eligibility Reviews Not Completed(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS and DWS did not complete the annual Medicaid eligibility reviews for 3 of 60 cases sampled. In addition, it did not complete an asset verification for one of these 3 cases. As required by 42 CFR 435.916, states must:? renew MAGI-based determinations of eligibility once every 12 months and no more frequently;? renew non-MAGI based eligibility at least once every 12 months.Section 721-1.A.1.b.i of the Utah Medicaid Policy Manual requires that asset verifications be completed as part of these eligibility reviews. Question 10 of the COVID-19 Q&A within Medicaid Policy states that when an eligibility review is due during the emergency period, it should ?follow [the] normal review policy in section 721.? While DHHS did not complete these reviews because individuals could not be removed from programs during the public health emergency, individuals could have be moved to more appropriate programs if their income or household composition changes. The lack of regular reviews could result in Medicaid customers receiving coverage that does not match their needs and could also prolong individuals? ineligible participation in programs once the emergency period ends.Recommendation:We recommend that DHHS perform annual reviews and asset verifications in accordance with its policy.DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Department of Workforce Services (DWS) to whom we have delegated authority to perform eligibility determinations for Medicaid and CHIP and will ensure that DWS properly follows policy sections 721-1.A.1.b.i and COVID-19 Q & A question 10. DWS will train staff on proper use of the asset verification system, as well as remind staff on the review policy. DWS? Performance Review Team will also review a sample of cases to ensure compliance with these policies.DWS?s Response:We agree with the finding.
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Required Audits of MCO Encounter and Financial Data Not Conducted(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Department of Health and Human Services (DHHS) did not conduct or contract for independent periodic audits of Managed Care Organization (MCO) encounter and financial data and did not post audit results as required by 42 CFR Section 438.602(e) & (g). No independent audits of the necessary data have been performed or contracted to date. DHHS staff believed audits of the Medical Loss Ratio (MLR) satisfied federal requirements. However, the MLR audits do not attest to the ?accuracy, truthfulness, and completeness? of an MCO?s encounter and financial data. Unaudited encounter data not available to the public for review reduces the transparency in the Medicaid Program and causes noncompliance with federal requirements.Recommendation:We recommend DHHS either conduct or contract for independent periodic audits of MCO data and post the audit results in accordance with 42 CFR 438.602(3) & (g).DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Utah OIG to audit these encounters and/or conduct these periodic audits with Medicaid staff. The results will be posted on the Utah Medicaid website.
Medical Loss Ratio Report Lacked Two Required Elements(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 1 of 2 Medical Loss Ratio (MLR) reports we reviewed, DHHS could not provide evidence that it had performed in a timely manner a review of the MLR report. Additionally, the MLR report did not contain two key reporting items. Specifically, the Pre-Paid Inpatient Health Plan (PIHP)?s MLR report was 1) missing the methodologies for the allocation of expenditures; and, 2) a signed attestation of accuracy. 42 CFR sections 438.8(k) and 438.8(n) require that ?the State must ensure that each. . . PIHP. . . submits a report with the data elements specified.? 2 CFR 300.303 also requires non-federal entities to ?establish and maintain effective internal control over the Federal award that provides reasonable assurance.? Inadequate reviews of MLR Reports may result in improper methodologies and inaccuracies in the MLR calculations to remain undetected.Recommendation:We recommend DHHS enforce the established internal controls over MLR reporting, and educate DHHS staff and Managed Care Plans of the Federal reporting requirements.DHHS?s Response:The Department concurs with this recommendation. The Department will ensure that all required elements of the MLR are received by having DHHS staff review elements of the MLR to ensure they are complete.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
Annual Medicaid Eligibility Reviews Not Completed(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS and DWS did not complete the annual Medicaid eligibility reviews for 3 of 60 cases sampled. In addition, it did not complete an asset verification for one of these 3 cases. As required by 42 CFR 435.916, states must:? renew MAGI-based determinations of eligibility once every 12 months and no more frequently;? renew non-MAGI based eligibility at least once every 12 months.Section 721-1.A.1.b.i of the Utah Medicaid Policy Manual requires that asset verifications be completed as part of these eligibility reviews. Question 10 of the COVID-19 Q&A within Medicaid Policy states that when an eligibility review is due during the emergency period, it should ?follow [the] normal review policy in section 721.? While DHHS did not complete these reviews because individuals could not be removed from programs during the public health emergency, individuals could have be moved to more appropriate programs if their income or household composition changes. The lack of regular reviews could result in Medicaid customers receiving coverage that does not match their needs and could also prolong individuals? ineligible participation in programs once the emergency period ends.Recommendation:We recommend that DHHS perform annual reviews and asset verifications in accordance with its policy.DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Department of Workforce Services (DWS) to whom we have delegated authority to perform eligibility determinations for Medicaid and CHIP and will ensure that DWS properly follows policy sections 721-1.A.1.b.i and COVID-19 Q & A question 10. DWS will train staff on proper use of the asset verification system, as well as remind staff on the review policy. DWS? Performance Review Team will also review a sample of cases to ensure compliance with these policies.DWS?s Response:We agree with the finding.
Use of Appropriate National Correct Coding Initiative (NCCI) Edit Files Not Verified(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not verify its third-party contractor?s use of appropriate National Correct Coding Initiative (NCCI) edit files. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with?terms and conditions of the federal award.? DHHS is required to use the most recent quarterly Medicaid NCCI edit files to ensure the proper payment of claims and to verify the correct edit files are used in processing claims. While DOH downloaded and sent the correct files to the third-party, it did not independently verify the third-party?s use of the updated edit files during the fiscal year. Because DHHS did not verify the use of the correct edit files, inaccurate, incomplete, or false claims could be paid.Recommendation:We recommend DHHS establish a system of regularly checking its third-party?s NCCI edits to ensure the correct edit files are used.DHHS?s Response and Corrective Action Plan:The Department concurs with this recommendation. The Division successfully created and tested a comparison file. The division will continue to work to resolve audit concerns. Implementation in production is set for November 2022.
Required Audits of MCO Encounter and Financial Data Not Conducted(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Department of Health and Human Services (DHHS) did not conduct or contract for independent periodic audits of Managed Care Organization (MCO) encounter and financial data and did not post audit results as required by 42 CFR Section 438.602(e) & (g). No independent audits of the necessary data have been performed or contracted to date. DHHS staff believed audits of the Medical Loss Ratio (MLR) satisfied federal requirements. However, the MLR audits do not attest to the ?accuracy, truthfulness, and completeness? of an MCO?s encounter and financial data. Unaudited encounter data not available to the public for review reduces the transparency in the Medicaid Program and causes noncompliance with federal requirements.Recommendation:We recommend DHHS either conduct or contract for independent periodic audits of MCO data and post the audit results in accordance with 42 CFR 438.602(3) & (g).DHHS?s Response:The Department concurs with this recommendation. The Department will coordinate with the Utah OIG to audit these encounters and/or conduct these periodic audits with Medicaid staff. The results will be posted on the Utah Medicaid website.
Medical Loss Ratio Report Lacked Two Required Elements(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 1 of 2 Medical Loss Ratio (MLR) reports we reviewed, DHHS could not provide evidence that it had performed in a timely manner a review of the MLR report. Additionally, the MLR report did not contain two key reporting items. Specifically, the Pre-Paid Inpatient Health Plan (PIHP)?s MLR report was 1) missing the methodologies for the allocation of expenditures; and, 2) a signed attestation of accuracy. 42 CFR sections 438.8(k) and 438.8(n) require that ?the State must ensure that each. . . PIHP. . . submits a report with the data elements specified.? 2 CFR 300.303 also requires non-federal entities to ?establish and maintain effective internal control over the Federal award that provides reasonable assurance.? Inadequate reviews of MLR Reports may result in improper methodologies and inaccuracies in the MLR calculations to remain undetected.Recommendation:We recommend DHHS enforce the established internal controls over MLR reporting, and educate DHHS staff and Managed Care Plans of the Federal reporting requirements.DHHS?s Response:The Department concurs with this recommendation. The Department will ensure that all required elements of the MLR are received by having DHHS staff review elements of the MLR to ensure they are complete.
Sufficiently-Detailed PIC Meeting Minutes Not Maintained(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.778 Medicaid Assistance ProgramFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS?s Program Integrity Committee (PIC) did not have well-documented meeting minutes showing the Office of Inspector General (OIG) reporting on utilization, fraud, waste, abuse, and recovery of Medicaid funds. 2 CFR 200.303 states that non-federal entities must ?establish and maintain effective internal control? that provides reasonable assurance that the non-federal entity is managing [the program] in compliance with? terms and conditions of the federal award.? PIC meetings were established so DHHS and OIG would meet monthly and report on utilization, fraud, waste, abuse, and recovery of Medicaid funds. However, it was recorded in only one of the seven monthly PIC meeting minutes that OIG reported on the required items. Staff turnover led to poorly recorded meeting minutes, which can result in incomplete, inaccurate, or untimely reporting of Medicaid funds abuse.Recommendation:We recommend that DHHS maintain detailed meeting minutes for its PIC meetings.DHHS?s Response:The Department concurs with this recommendation. The MOU between OIG and DIH/Medicaid and the PIC bylaws define that meeting minutes will be taken with each PIC Committee. These meeting minutes will be reviewed at the following PIC Committee meeting and voted on for approval.PIC bylaws specifically state:?To keep written minutes of all Committee meetings, with assistance of staff, including:? Date, time, and place of meeting;? Names of members present, absent, and excused;? Substance of all matters proposed, discussed or decided and a record of votes taken;? Names of all other individuals who appeared and the substance in brief of their testimony;? Any other information that any member requests to be entered in the minutes.?
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Foster Care Eligibility Controls Not Completed in a Timely Manner(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.658 Foster Care Title IV-EFederal Award Number: 2201UTFOST; 2101UTFOSTQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor 16 of 40 (40%) of cases reviewed, the State of Utah?s Department of Health & Human Services (DHHS) could not provide evidence that it had reviewed the initial Title IV-E Foster Care eligibility decision. 2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? The control was not properly designed and implemented as only two people (one of which is only a part time worker with responsibilities for other programs) were working on reviews for all Foster Care cases. The available resources are insufficient to complete these reviews in a timely manner. Unreviewed or untimely reviews of eligibility decisions could lead to improper eligibility determinations and inappropriate benefit payments.Recommendation:We recommend DHHS provide sufficient resources to carry out the existing control or modify the control to ensure eligibility decisions are reviewed in a timely manner.DHHS?s Response:The Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DHHS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Subawards for SAPT Not Included in FFATA Reports(Department of Health and Human Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.959 Substance Abuse and Prevention TreatmentFederal Award Number: 6B08TI010052-19M0016B08TI083039-01M0046B08TI083479-01M0041B08TI083546-016B08TI084674-01M002Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/ADHHS did not have adequate controls implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. None of the Substance Abuse and Prevention Treatment (SAPT) subawards with FFATA reporting requirements were reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Since DHHS was unable to provide a SAPT subaward list, we could not determine the number of subawards and associated dollar amounts that should have been reported in FSRS.2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DHHS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported in FSRS ?no later than the end of the month following the month in which the obligation was made.? Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DHHS improve internal controls to capture applicable subawards in order to ensure accurate and timely FFATA reporting.DHHS?s Response:The Department concurs with this recommendation. We agree to properly report the subaward information beginning with SFY23.
Working Capital Reserves in Excess of Federal Guidelines(Department of Government Operations)Federal Agency: VariousAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: UndeterminablePass-through Entity: NonePrior Year Single Audit Report Finding Number: 2021-025,2020-036; 2019-023; 2018-033; 2017-021; 2016-037; 2015-048; 2014-040; 2013-049; 2012-51; 2011-56As of June 30, 2022, four divisions within the Department of Government Operations (DGO) held working capital reserves in excess of federal guidelines of at least the amount that follows: (see the Schedule of Findings and Questioned Costs for the table)The following divisions do not have excess reserves at the internal service fund level, however, the federal oversight agency requires them to be assessed at the service area level, which resulted in excess reserves as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200, Appendix V, paragraph G.2, generally allows a working capital reserve as part of retained earnings of up to 60 days? cash expenses for normal operating purposes in each internal service fund. For DTS, the federal oversight agency only allows 45 days. The excess reserves were due to the inherent difficulty of accurately estimating expenses when setting rates. Excess reserves could result in a federal liability since federal programs share an interest in the reserves.Recommendation:Depending on the business requirements, we recommend each division within DGO reduce excess working capital reserves within each of the respective funds or service areas or obtain a waiver for an increase in the number of days of working capital allowed to comply with federal guidelines.DGO?s Response:Division of Purchasing and General ServicesCooperative Contract Management ? Public entities in Utah rely on the Division of Purchasing and General Services (State Purchasing) to maintain the cooperative contract program to help with public procurement in Utah. The usage of state cooperative contracts by public entities increased dramatically this past year resulting in a corresponding increase in the collection of administrative fees. State Purchasing still continues to decrease the administrative fees on state cooperative contracts as each contract expires and is rebid. This is a slow process since State Purchasing has nearly 1,200 cooperative contracts that expire only every five years. Although State Purchasing is allowed under law to collect up to a 1.0% administrative fee on each cooperative contract, currently the average administrative fee is 0.38%. State Purchasing has also requested the Utah Legislature to appropriate out a portion of the excess reserves in this fund in fiscal year 2023. The calculation for the refund of the federal portion of this transfer out will be submitted to Cost Allocation Services for review and approval when this transfer is complete.Federal and State Surplus Property - Due to the completion of the new Utah State Prison, Surplus Property anticipates relocating by the end of calendar year 2023. At that time, Federal and State Surplus will need to use their working capital reserve funds for the costs of moving to and furnishing their new location. These additional expenses should eliminate these excess reserves by December 2023.Purchasing Cards ? The Division of Finance (State Finance) is in the process of implementing a new travel and expense reporting system for all State agencies to simplify travel approvals, travel reimbursements, and reduce the administrative burden for the purchasing card (p-card) expense reports on State agency personnel. To cover system implementation costs, State Finance elected not to distribute the rebates received from U.S. Bank related to State agency p-card spending for calendar years 2021 and 2022. Rebates were still passed through to participating entities external to the primary government. The anticipated completion date for the system is the end of calendar year 2023. State Finance will review annually the costs of the system, develop a cost allocation strategy between the Travel and P-Card programs, adjust travel rates to cover the travel program?s ongoing costs, and distribute any remaining p-card rebates to State agencies respective to their spend. This effort will reduce and/or eliminate excess federal reserves by the end of fiscal year 2024.Division of Risk ManagementWorkers? Compensation Fund & Property? We requested approval in the current legislative session to transfer $2,000,000 out of the Workers Compensation Fund and into the Property Fund. We will submit the calculation for the refund of the federal portion of this transfer to Cost Allocation Services for their review and approval when this transfer is completed. Additionally, in FY 2023, the premiums charged for workers compensation have been reduced 26% from $0.61 per $100 to $0.45 per $100. The property commercial insurance market and the Property Fund are experiencing enormous year-over-year premium increases. We have seen a doubling of premiums in the last five years, from $14,000,000 to $28,000,000. Additionally, the budget process requires that we project funding 1-2 years in advance before we can enact rate increases to pay the excess insurance premiums that are due each fiscal year. As such, we deem it important to maintain a retained earnings balance in the Property Fund to be able to sustain the Fund's ability to pay for increasing premiums.Division of Technology ServicesPrint Services ? DTS currently projects Print Services retained earnings will decrease by $181 thousand in fiscal year 2023. The Print Services rate was set lower than the cost to provide this service in fiscal year 2024. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Print Services into compliance with federal excess reserve guidelines by the end of fiscal year 2024.Communication Services - The fiscal year 2024 rate was set to under recover the cost of providing this service by an additional $425 thousand. Because the reductions to retained earnings were smaller than expected in fiscal year 2022 and are projected to be smaller than expected in fiscal year 2023, DTS will need an additional year to address this excess. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Communication Services into compliance with federal excess reserve guidelines by the end of fiscal year 2025.Network Services - DTS anticipates significant expenses to this product in fiscal year 2023 as DTS upgrades the aging network infrastructure and as the demand for network services continues to increase (e.g. Agencies are asking for increased bandwidth). Upgrades to the infrastructure have been more complex than originally estimated, which has delayed the majority of this expense to fiscal year 2023. DTS projects the Network Services retained earnings will decrease by nearly $1 million in fiscal year 2023. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Network Services into compliance with federal excess reserve guidelines by the end of fiscal year 2023.Mainframe Services - This product will be coming to an end by fiscal year 2024. As the product ends, DTS will issue a rebate to reduce retained earnings to the agencies using the system. DTS plans to issue a credit in fiscal year 2023 which will bring Mainframe Services into compliance.Division of Human Resource ManagementHuman Resources Core Services - The Division of Human Resource Management (DHRM) projects DHRM Core Services expenses to increase in fiscal year 2023 and future years. The DHRM Core Services excess reserves was the result of an error correction. In an effort to decrease these excess reserves, DHRM has not requested a rate increase for DHRM Core Services, though we do anticipate costs to increase. We will continue to annually review and adjust the DHRM Core Services rate and, if necessary, issue refunds or rebates to ensure DHRM Core Services is in compliance with federal excess reserve guidelines by the end of fiscal year 2024.
Working Capital Reserves in Excess of Federal Guidelines(Public Employees Health Plan)Federal Agency: VariousAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: UndeterminablePass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-026; 2020-039; 2019-026; 2018-036; 2017-023; 2016-039; 2015-050; 2014-042; 2013-050; 2012 12-53; 2011 11-58As of June 30, 2022, the Public Employees Health Program (PEHP) held working capital reserves in excess of federal guidelines as follows below. (See Schedule of Findings and Questioned Costs for the table)2 CFR part 200, Appendix V, paragraph G.2, generally allows a working capital reserve as part of retained earnings of up to 60 days? cash expenses for normal operating purposes. The inherent difficulty of accurately estimating expenses led to excess reserves. Excess reserves could result in a federal liability since federal programs share an interest in the reserves. Recommendation:Depending on the business requirements, we recommend PEHP:1. Reduce excess working capital reserves, or2. Obtain a waiver from the federal cost negotiator allowing an increase in the number of days of working capital allowed to comply with federal guidelines.PEHP?s Response:Long-term DisabilityPEHP operates as a fully functioning third party-administrator for Long-term Disability benefits for the state of Utah and other public entities in Utah. Consequently, the reserves that PEHP holds and administers for the state of Utah do not relate to the payment of premium but the payment of ongoing, multi-year benefits for plan participants. These are vested benefits that PEHP would be required to pay on behalf the state for plan recipients, even if the program was discontinued and premiums were no longer collected. Because of this, PEHP will return excess premiums identified by our outside actuary while also seeking to obtain a waiver from the federal cost negotiator during 2023 to allow an increase in the number of days of working capital in compliance with federal guidelines.Medicare SupplementPEHP operates as a fully functioning third party-administrator for Medicare Supplement and Part D benefits for the state of Utah and other public entities in Utah. Consequently, the reserves that PEHP holds and administers for the state of Utah do not relate to the payment of premium but the payment of ongoing benefits for plan participants. During 2023, PEHP will seek to obtain a waiver from the federal cost negotiator to allow an increase in the number of days of working capital in compliance with federal guidelines on three grounds. First, the volatile nature of Part D pharmacy claims. Second, the relatively small dollar amount associated with Medicare premiums that can create a higher level of potential volatility. Third, the relatively small number of members covered by PEHP?s Medicare products that can also create a higher level of potential volatility.