Audit 330185

Finding 2024-001 Significant Deficiency: Reporting - Control Finding ALN: 93.558 - 477 Cluster: Temporary Assistance for Needy Families (TANF) Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Family and Children's Services of Missouri Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place, and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of monthly financial reimbursement reports to ensure accuracy prior to the reports being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of financial reimbursement reports was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: 4 out of 4 monthly reimbursement reports tested did not have proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these reports to an individual who is knowledgeable of the program to ensure that reports are complete and accurate prior to submission, and that such reviews are documented. Views of Responsible Officials: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. The Archdiocese Finance Office accountant will prepare monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports, then submit them via email with approvals for reimbursement.

Finding 2024-001 Significant Deficiency: Reporting - Control Finding ALN: 93.558 - 477 Cluster: Temporary Assistance for Needy Families (TANF) Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Family and Children's Services of Missouri Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place, and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of monthly financial reimbursement reports to ensure accuracy prior to the reports being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of financial reimbursement reports was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: 4 out of 4 monthly reimbursement reports tested did not have proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these reports to an individual who is knowledgeable of the program to ensure that reports are complete and accurate prior to submission, and that such reviews are documented. Views of Responsible Officials: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. The Archdiocese Finance Office accountant will prepare monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports, then submit them via email with approvals for reimbursement.

Finding 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Control Finding ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Social Services Criteria or Specific Requirement: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions. Views of Responsible Officials: St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.

Finding 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Control Finding ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Social Services Criteria or Specific Requirement: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions. Views of Responsible Officials: St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.

Finding 2024-001 Significant Deficiency: Reporting - Control Finding ALN: 93.558 - 477 Cluster: Temporary Assistance for Needy Families (TANF) Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Family and Children's Services of Missouri Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place, and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of monthly financial reimbursement reports to ensure accuracy prior to the reports being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of financial reimbursement reports was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: 4 out of 4 monthly reimbursement reports tested did not have proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these reports to an individual who is knowledgeable of the program to ensure that reports are complete and accurate prior to submission, and that such reviews are documented. Views of Responsible Officials: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. The Archdiocese Finance Office accountant will prepare monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports, then submit them via email with approvals for reimbursement.

Finding 2024-001 Significant Deficiency: Reporting - Control Finding ALN: 93.558 - 477 Cluster: Temporary Assistance for Needy Families (TANF) Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Family and Children's Services of Missouri Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place, and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of monthly financial reimbursement reports to ensure accuracy prior to the reports being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of financial reimbursement reports was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: 4 out of 4 monthly reimbursement reports tested did not have proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these reports to an individual who is knowledgeable of the program to ensure that reports are complete and accurate prior to submission, and that such reviews are documented. Views of Responsible Officials: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. The Archdiocese Finance Office accountant will prepare monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports, then submit them via email with approvals for reimbursement.

Finding 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Control Finding ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Social Services Criteria or Specific Requirement: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions. Views of Responsible Officials: St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.

Finding 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Control Finding ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Social Services Criteria or Specific Requirement: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions. Views of Responsible Officials: St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.