Audit 315423

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to monitor funds that are passed through to subrecipients and the continued stewardship of those federal dollars. Condition – For the year ended December 31, 2023, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community Services Block Grant (CSBG). Although the policies and procedures in effect during the year ended December 31, 2023 were appropriately designed, they were not completed throughout the year. Cause – There was a general misunderstanding between staff and management on the process of completing subrecipient monitoring controls throughout the year. Effect – Noncompliance will not be prevented, or detected and corrected in a timely manner Question costs – None. Repeat Finding – This is not a repeat finding. Recommendation – The subrecipient monitoring policies and procedures should be updated to include specific milestones and broken down into specific tasks that are to be achieved throughout the year. These could then be monitored through meetings between the board treasurer and the CSBG program coordinator. Redundancies and cross-training could be included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the year over CSBG policies and procedures would allow for better clarity and understanding. Views of Responsible Officials – Management recognized the deficiency and plans to implement the auditor’s recommendation.

Federal Programs – AL 93.569 – Community Services Block Grant Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes the review of independent audits of subrecipients and response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient monitoring policy, requested supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Uniform Guidance for subrecipient monitoring and per CAPND's internal policies could not be substantiated or were determined to not have occurred during the year under audit. Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring requirement was not in compliance during the current year. Context– Of the total federal expenditures under the program noted above, $276,165 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with CAPND staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the five subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the five subawards awarded to pass-through entities, all five were missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient's unique entity identifier. o Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Question costs – None. Repeat Finding – This is not a repeat finding.