Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Award requires compliance with the provisions
of procurement, suspension, and debarment. The Organization should have internal controls
designed to ensure compliance with those provisions.
Condition: During our testing, it was noted that the Organization did not implement policies and
procedures over procurement, suspension, and debarment under Uniform Grant Guidance in
the year under audit.
Questioned Costs: None
Context: In a sample of 8, 7 did not follow 2 CFR Part 200 Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Award provisions of
procurement, suspension, and debarment.
Cause: The Organization is in the startup phases and the Uniform Grant Requirements are new
as 2022 was the first year federal funding was received. Procurement, suspension, and
debarment procedures were not yet in place when getting the Organization's operations started.
Effect: The auditor noted no instances of noncompliance with the provisions of procurement,
suspension, and debarment; however, the lack of internal controls over these compliance
requirements provides an opportunity for noncompliance.
Repeat finding: No
Recommendation: We recommend that management implement policies and procedures over
procurement and suspension and debarment under Uniform Grant Guidance going forward.Views of responsible officials: We agreed with the above comment. The Organization will put
in place a policy and procedure over procurement and suspension and debarment under
Uniform Grant Guidance and will consult with external auditors.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly Project and
Expenditure Reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors
in reporting.
Questioned Costs: None
Context: During our testing, it was noted that there was no formal layer of review over the
quarterly report prepared before it was submitted to the grantor.
Cause: The Organization is in the startup phases and maintaining current operations with
limited staff.
Effect: The auditor noted no instances of noncompliance with the provisions of reporting;
however, the lack of internal controls over this compliance requirement provides an opportunity
for noncompliance.
Repeat finding: No
Recommendation: We recommend that reports are prepared and reviewed by separate
individuals.
Views of responsible officials: We agreed with the above comment. The Organization will put
a formal layer of review after preparation of the report and before submission to the grantor.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance with respect to record
retention
Specific requirement-criteria: The Organization is required to provide support that internal
controls over compliance are in place.
Condition: Internal controls over compliance of allowable costs were not in place to support
that the organization had implemented controls to prevent, detect, or correct errors in calculating
provider payments or payroll that were allocated to the federal program.
Questioned costs: None
Context:
Provider Payments
Providers payments calculations are not reviewed for errors by a separate individual. In a
sample of 20, the amount used in the calculation for 7 providers was higher than the maximum
award amount per the provider agreement. A copy of the signed provider agreement was not
consistently retained by the Organization.
In a sample of 20, 1 attendance sheet did not support the attendance number used in the
provider payment calculation. The lack of controls over the calculation resulted in an
overpayment to the provider of less than $1,000.
Payroll
In a sample of 2, there was no record of timesheet approval by a supervisor or of the overall
approval of the associated payroll register. There was no record of the approved pay rate for 1
of the 2 items selected. Cause: The Organization is in the startup phases and the Uniform Grant Requirements are new
as 2022 was the first year federal funding was received. Formal policies and procedures over
record retention were not yet in place when getting the Organization's operations started.
Effect or potential effect: The amounts paid to providers, employees, or vendors could be
improperly calculated resulting in an error in the funds covered under the federal grant.
Repeat finding: No
Recommendation: We recommend that management continue to recruit for staff to fill the
needed positions in the finance department as they continue to grow.
Management response: We agreed with the above comment and are actively recruiting for
positions in the finance department.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Award requires compliance with the provisions
of procurement, suspension, and debarment. The Organization should have internal controls
designed to ensure compliance with those provisions.
Condition: During our testing, it was noted that the Organization did not implement policies and
procedures over procurement, suspension, and debarment under Uniform Grant Guidance in
the year under audit.
Questioned Costs: None
Context: In a sample of 8, 7 did not follow 2 CFR Part 200 Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Award provisions of
procurement, suspension, and debarment.
Cause: The Organization is in the startup phases and the Uniform Grant Requirements are new
as 2022 was the first year federal funding was received. Procurement, suspension, and
debarment procedures were not yet in place when getting the Organization's operations started.
Effect: The auditor noted no instances of noncompliance with the provisions of procurement,
suspension, and debarment; however, the lack of internal controls over these compliance
requirements provides an opportunity for noncompliance.
Repeat finding: No
Recommendation: We recommend that management implement policies and procedures over
procurement and suspension and debarment under Uniform Grant Guidance going forward.Views of responsible officials: We agreed with the above comment. The Organization will put
in place a policy and procedure over procurement and suspension and debarment under
Uniform Grant Guidance and will consult with external auditors.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly Project and
Expenditure Reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors
in reporting.
Questioned Costs: None
Context: During our testing, it was noted that there was no formal layer of review over the
quarterly report prepared before it was submitted to the grantor.
Cause: The Organization is in the startup phases and maintaining current operations with
limited staff.
Effect: The auditor noted no instances of noncompliance with the provisions of reporting;
however, the lack of internal controls over this compliance requirement provides an opportunity
for noncompliance.
Repeat finding: No
Recommendation: We recommend that reports are prepared and reviewed by separate
individuals.
Views of responsible officials: We agreed with the above comment. The Organization will put
a formal layer of review after preparation of the report and before submission to the grantor.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Period: July 1, 2022 through December 31, 2023
Type of Finding:
• Significant Deficiency in Internal Control over Compliance with respect to record
retention
Specific requirement-criteria: The Organization is required to provide support that internal
controls over compliance are in place.
Condition: Internal controls over compliance of allowable costs were not in place to support
that the organization had implemented controls to prevent, detect, or correct errors in calculating
provider payments or payroll that were allocated to the federal program.
Questioned costs: None
Context:
Provider Payments
Providers payments calculations are not reviewed for errors by a separate individual. In a
sample of 20, the amount used in the calculation for 7 providers was higher than the maximum
award amount per the provider agreement. A copy of the signed provider agreement was not
consistently retained by the Organization.
In a sample of 20, 1 attendance sheet did not support the attendance number used in the
provider payment calculation. The lack of controls over the calculation resulted in an
overpayment to the provider of less than $1,000.
Payroll
In a sample of 2, there was no record of timesheet approval by a supervisor or of the overall
approval of the associated payroll register. There was no record of the approved pay rate for 1
of the 2 items selected. Cause: The Organization is in the startup phases and the Uniform Grant Requirements are new
as 2022 was the first year federal funding was received. Formal policies and procedures over
record retention were not yet in place when getting the Organization's operations started.
Effect or potential effect: The amounts paid to providers, employees, or vendors could be
improperly calculated resulting in an error in the funds covered under the federal grant.
Repeat finding: No
Recommendation: We recommend that management continue to recruit for staff to fill the
needed positions in the finance department as they continue to grow.
Management response: We agreed with the above comment and are actively recruiting for
positions in the finance department.