Audit 319246

FY End
2021-09-30
Total Expended
$9.93M
Findings
28
Programs
16
Year: 2021 Accepted: 2024-09-10

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
496357 2021-101 Material Weakness Yes N
496358 2021-101 Material Weakness Yes N
496359 2021-101 Material Weakness - N
496360 2021-101 Material Weakness Yes N
496361 2021-101 Material Weakness - N
496362 2021-102 Material Weakness Yes L
496363 2021-102 Material Weakness Yes L
496364 2021-102 Material Weakness - L
496365 2021-102 Material Weakness Yes L
496366 2021-102 Material Weakness - L
496367 2021-103 Material Weakness - C
496368 2021-103 Material Weakness Yes C
496369 2021-103 Material Weakness - C
496370 2021-104 Significant Deficiency - E
1072799 2021-101 Material Weakness Yes N
1072800 2021-101 Material Weakness Yes N
1072801 2021-101 Material Weakness - N
1072802 2021-101 Material Weakness Yes N
1072803 2021-101 Material Weakness - N
1072804 2021-102 Material Weakness Yes L
1072805 2021-102 Material Weakness Yes L
1072806 2021-102 Material Weakness - L
1072807 2021-102 Material Weakness Yes L
1072808 2021-102 Material Weakness - L
1072809 2021-103 Material Weakness - C
1072810 2021-103 Material Weakness Yes C
1072811 2021-103 Material Weakness - C
1072812 2021-104 Significant Deficiency - E

Contacts

Name Title Type
XAMYJM738669 Deserea Quintana Auditee
7753550600 Jay Parke Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of Accounting Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: ITCN has an approved indirect cost rate for the year ended September 30, 2021, of 15% for HeadStart, 19.2% for Native American Employment, and 18.1% for all other grants; therefore, ITCN did not elect to use the 10 percent de minimis indirect cost rate covered in 2 CFR §200.414. The accompanying schedule of expenditures of federal awards (schedule) includes Inter-Tribal Council of Nevada, Inc.’s (ITCN) federal grant activity for the year ended September 30, 2021. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).
Title: Note 2 - Indirect Cost Rate Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: ITCN has an approved indirect cost rate for the year ended September 30, 2021, of 15% for HeadStart, 19.2% for Native American Employment, and 18.1% for all other grants; therefore, ITCN did not elect to use the 10 percent de minimis indirect cost rate covered in 2 CFR §200.414. ITCN has an approved indirect cost rate for the year ended September 30, 2021, of 15% for HeadStart, 19.2% for Native American Employment, and 18.1% for all other grants; therefore, ITCN did not elect to use the 10 percent de minimis indirect cost rate covered in 2 CFR §200.414.
Title: Note 3 - Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: ITCN has an approved indirect cost rate for the year ended September 30, 2021, of 15% for HeadStart, 19.2% for Native American Employment, and 18.1% for all other grants; therefore, ITCN did not elect to use the 10 percent de minimis indirect cost rate covered in 2 CFR §200.414. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements.
Title: Note 4 – Federal Assistance Listings (FAL) Number Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: ITCN has an approved indirect cost rate for the year ended September 30, 2021, of 15% for HeadStart, 19.2% for Native American Employment, and 18.1% for all other grants; therefore, ITCN did not elect to use the 10 percent de minimis indirect cost rate covered in 2 CFR §200.414. The program titles and FAL numbers were obtained from the federal or pass-through grantor or the 2021 Federal Assistance Listings.

Finding Details

Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: The program guidelines require each agency to provide nutrition education to each participant. For one of forty participants tested, documentation was not available to evidence that a participant had received the required nutrition education. Criteria: 7 CFR §246.11, Nutrition education, requires agencies to provide nutrition education, including breastfeeding promotion and support, as a benefit of the program at no cost to the participant. Cause and Effect: The cause is due to lack of resources and oversight at ITCN’s offices. The effect is potentially providing benefits to participants that are not eligible under the WIC guidelines. Recommendation: We recommend that ITCN adhere to its policy of providing nutrition education to each participant. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.
Condition and Context: The program guidelines require each agency to provide nutrition education to each participant. For one of forty participants tested, documentation was not available to evidence that a participant had received the required nutrition education. Criteria: 7 CFR §246.11, Nutrition education, requires agencies to provide nutrition education, including breastfeeding promotion and support, as a benefit of the program at no cost to the participant. Cause and Effect: The cause is due to lack of resources and oversight at ITCN’s offices. The effect is potentially providing benefits to participants that are not eligible under the WIC guidelines. Recommendation: We recommend that ITCN adhere to its policy of providing nutrition education to each participant. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.