United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Significant deficiency over Procurement and Suspension and Debarment
Repeat Finding: No
Condition:
During our audit we noted that procurement documentation was not available to support the
selection of a sole source vendor. Also, we were unable to obtain documentation to support BCI
entering into contractual agreements with vendors who were not debarred or suspended from
doing business with the Federal government.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
Per 2 CFR 200.320 General procurement stands:
(a) Noncompetitive procurement. There are specific circumstances in which noncompetitive
procurement can be used. Noncompetitive procurement can only be awarded if one or more of
the following circumstances apply: (1) The acquisition of property or services, the aggregate
dollar amount of which does not exceed the micro-purchase threshold .(2) The item is available
only from a single source; (3) The public exigency or emergency for the requirement will not
permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding
agency or pass-through entity expressly authorizes a noncompetitive procurement in response to
a written request from the non-Federal entity; or (5) After solicitation of a number of sources,
competition is determined inadequate.
Per 2 CFR 200.318 General procurement stands:
(b) The Non-Federal entity must use its own documented procurement procedures which reflect
applicable State, local, and tribal laws and regulations, provided that the procurements conform
to applicable Federal law and the standards identified in this part.
Per Uniform Guidance, Non-Federal entities are prohibited from contracting with or making
subawards under covered transactions to parties that are suspended or debarred. “Covered
transactions” include contracts for goods and services awarded under a non-procurement
transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or
meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement
transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective
of award amount, are considered covered transactions, unless they are exempt as provided in 2
CFR section 180.215.
Cause:
BCI did not apply the required procurement policy relative to sole source contracts in accordance
with Uniform Guidance. Management also did not complete a review of vendors/contractors to
verify they are not suspended, debarred, or otherwise excluded before contracting.
Effect:
The Organization does not have adequate documentation on whether they have entered into
transactions with eligible entities and is in compliance with Federal guidelines.
Questioned Costs:
Unknown
Recommendation:
We recommend the Organization update and follow their controls to identify vendors that should
go through the procurement process. We also recommend the Organization follow their process
to verify that entities are not suspended, debarred, or otherwise excluded annually at time of
award and to document these procedures.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Significant deficiency over Procurement and Suspension and Debarment
Repeat Finding: No
Condition:
During our audit we noted that procurement documentation was not available to support the
selection of a sole source vendor. Also, we were unable to obtain documentation to support BCI
entering into contractual agreements with vendors who were not debarred or suspended from
doing business with the Federal government.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
Per 2 CFR 200.320 General procurement stands:
(a) Noncompetitive procurement. There are specific circumstances in which noncompetitive
procurement can be used. Noncompetitive procurement can only be awarded if one or more of
the following circumstances apply: (1) The acquisition of property or services, the aggregate
dollar amount of which does not exceed the micro-purchase threshold .(2) The item is available
only from a single source; (3) The public exigency or emergency for the requirement will not
permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding
agency or pass-through entity expressly authorizes a noncompetitive procurement in response to
a written request from the non-Federal entity; or (5) After solicitation of a number of sources,
competition is determined inadequate.
Per 2 CFR 200.318 General procurement stands:
(b) The Non-Federal entity must use its own documented procurement procedures which reflect
applicable State, local, and tribal laws and regulations, provided that the procurements conform
to applicable Federal law and the standards identified in this part.
Per Uniform Guidance, Non-Federal entities are prohibited from contracting with or making
subawards under covered transactions to parties that are suspended or debarred. “Covered
transactions” include contracts for goods and services awarded under a non-procurement
transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or
meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement
transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective
of award amount, are considered covered transactions, unless they are exempt as provided in 2
CFR section 180.215.
Cause:
BCI did not apply the required procurement policy relative to sole source contracts in accordance
with Uniform Guidance. Management also did not complete a review of vendors/contractors to
verify they are not suspended, debarred, or otherwise excluded before contracting.
Effect:
The Organization does not have adequate documentation on whether they have entered into
transactions with eligible entities and is in compliance with Federal guidelines.
Questioned Costs:
Unknown
Recommendation:
We recommend the Organization update and follow their controls to identify vendors that should
go through the procurement process. We also recommend the Organization follow their process
to verify that entities are not suspended, debarred, or otherwise excluded annually at time of
award and to document these procedures.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
United States Department of Treasury
Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA)
Federal Assistance Listing No. 94.006 AmeriCorps State and National
Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost
Principle (Payroll)
Repeat Finding: No
Condition:
For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the
AmeriCorps and ARPA programs were for actual time and effort spent on the grant.
Criteria:
In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides
guidance on internal controls over Federal programs based upon the guidance in Standards for
Internal Control in the Federal Government issued by the Comptroller General of the United
States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO). COSO requires entities to establish and
maintain effective internal controls to achieve operational, reporting and compliance objectives.
In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1)
Charges to Federal awards for salaries and wages must be based on records that accurately
reflect the work performed. These records must: (i) Be supported by a system of internal control
which provides reasonable assurance that the charges are accurate, allowable, and properly
allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably
reflect the total activity for which the employee is compensated by the non-Federal entity, not
exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other
activities compensated by the non-Federal entity on an integrated basis, but may include the use
of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the
established accounting policies and practices of the non-Federal entity; and (vi) Support the
distribution of the employee’s salary or wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal award; an
indirect cost activity and a direct cost activity; two or more indirect activities which are allocated
using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Cause:
BCI did not have proper controls in place to ensure that payroll activities charged were based on
actual work performed on the grant.
Effect:
BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for
the ARPA program. Unallowed payroll costs could be charged to the grant.
Questioned Costs:
Unknown.
Recommendation:
We recommend that BCI establish written procedures related to federally funded payroll (partial
and full) to ensure the charges are based on time and effort spent working on the grant and
implement these procedures immediately.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.
Significant Deficiency and Noncompliance Over Reporting
Repeat Finding: No
Condition:
BCI’s single audit report and the data collection form were not completed within nine months
after the end of the audit period.
Criteria:
Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the
data collection form described in paragraph (b) of this section and reporting package described in
paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt
of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on
a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2)
Unless restricted by Federal statutes or regulations, the auditee must make copies available for
public inspection. Auditees and auditors must ensure that their respective parts of the reporting
package do not include protected personally identifiable information.
Cause:
BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine
months after the end of the audit period. BCI did not have the policies and resources in place to
complete a single audit in a timely manner.
Effect:
Failure to submit the reporting package and data collection form within the required timeframe
results in non-compliance with the Uniform Guidance reporting requirements.
Questioned Costs:
None.
Recommendation:
We recommend that BCI creates policies and procedures to ensure that audits are started and
completed in a timely fashion so the reporting package submission to the Federal government
can be made in accordance with Federal guidelines. We also recommend that individuals
responsible for administering Federal assistance programs with BCI receive training in grant
administration.
Auditee Response and Corrective Action Plan:
Management agrees with the finding. Refer to the Corrective Action Plan.
Auditor’s Conclusion:
Finding remains as stated.