2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.
2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.
2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.
2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.
2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.
2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls
over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: The Organization did not conduct a physical inventory in current year or prior year.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish
and maintain effective internal control over the Federal award that provides reasonable assurance
that the non‐Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results
reconciled with the property records at least once every 2 years.
Questioned costs: None
Effect: The Organization could dispose of, lose, or encumber federally funded equipment without
following Federal guidelines.
Cause: The Organization does not have policies and procedures to ensure that a physical inventory of
equipment is performed at a minimum frequency of every two years.
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.
2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant
Deficiency in Internal Controls over Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2023
Condition: During our review of transactions, appropriate approval was not included in supporting
documents. The following were noted:
In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates
on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after
the expenditure was paid out.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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 Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government” issued by
the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued
by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Questioned costs: None
Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay
not being caught in a timely manner; or in misallocations to grants not being caught in a timely
manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking
account account.
Cause: The Organization is not following its policies and procedures to ensure the appropriate
approvals are conducted in a timely manner.