Audit 347428

Criteria or specific requirement – Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. Condition and Context – CSS awarded dollars to subrecipients in excess of $30,000 during fiscal year 2024 and no FFATA reports were filed. Effect – CSS did not meet Federal requirements. Cause – There is currently no system in place to track reporting deadlines and submissions. Repeat finding – No. Recommendation – We recommend CSS work to establish an internal tracking system to memorialize reporting deadlines by grant agreement and track the submission of required reports as outlined in the grant agreement. Views of Responsible Officials – Management agrees with the finding and recommendation.

Criteria or specific requirement – Non-federal entities must establish written procedures and internal controls over the request for and reimbursement of federal funds. Condition – One individual prepares and processes the request for Federal funds. There is no approval of the reimbursement request prior to the amounts being submitted to the Federal or non-Federal agency for reimbursement. Context – Of the 11 drawdowns available, we randomly selected three drawdowns for testing. Our random sample was not, nor intended to be, statistically valid. For each drawdown selected, there was no documentation to support CSS had the proper controls in place to review and approve the drawdown before submitting the reimbursement request. Effect – Drawdown requests could be prepared incorrectly. Cause – CSS did not have the appropriate controls in place over the cash management process. Repeat finding – No. Recommendation – We recommend CSS establish written procedures and internal controls over the request for and reimbursement of federal funds. Views of Responsible Officials – Management agrees with the finding and recommendation.

Criteria or specific requirement – A non-federal entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statues, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must review financial and performance reports; ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward such as single audit findings related to the subaward, issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity, and resolve audit findings specifically related to the subaward. Condition – For one of the subrecipients selected for testing, CSS noted that monitoring is not completed. Context – Of the eight subrecipients that received pass-through funding from CSS, we randomly selected three for testing. Our random sample was not, nor intended to be, statistically valid. One of the three subrecipients was not monitored appropriately. Effect – The subrecipient may have findings related to the grant funding provided by CSS which were unknown and not adequately addressed by CSS. Cause – CSS did not have the appropriate controls in place over the subrecipient monitoring process. Repeat finding – No. Recommendation – We recommend CSS revise their procedures to include all subrecipients in their monitoring procedures, obtaining audit reports for all subrecipients to ensure there are no audit findings related to the subaward and issue management decisions for any audit findings that are identified. Views of Responsible Officials – Management agrees with the finding and recommendation.

Criteria or specific requirement – Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. Condition and Context – CSS awarded dollars to subrecipients in excess of $30,000 during fiscal year 2024 and no FFATA reports were filed. Effect – CSS did not meet Federal requirements. Cause – There is currently no system in place to track reporting deadlines and submissions. Repeat finding – No. Recommendation – We recommend CSS work to establish an internal tracking system to memorialize reporting deadlines by grant agreement and track the submission of required reports as outlined in the grant agreement. Views of Responsible Officials – Management agrees with the finding and recommendation.

Criteria or specific requirement – Non-federal entities must establish written procedures and internal controls over the request for and reimbursement of federal funds. Condition – One individual prepares and processes the request for Federal funds. There is no approval of the reimbursement request prior to the amounts being submitted to the Federal or non-Federal agency for reimbursement. Context – Of the 11 drawdowns available, we randomly selected three drawdowns for testing. Our random sample was not, nor intended to be, statistically valid. For each drawdown selected, there was no documentation to support CSS had the proper controls in place to review and approve the drawdown before submitting the reimbursement request. Effect – Drawdown requests could be prepared incorrectly. Cause – CSS did not have the appropriate controls in place over the cash management process. Repeat finding – No. Recommendation – We recommend CSS establish written procedures and internal controls over the request for and reimbursement of federal funds. Views of Responsible Officials – Management agrees with the finding and recommendation.

Criteria or specific requirement – A non-federal entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statues, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must review financial and performance reports; ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward such as single audit findings related to the subaward, issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity, and resolve audit findings specifically related to the subaward. Condition – For one of the subrecipients selected for testing, CSS noted that monitoring is not completed. Context – Of the eight subrecipients that received pass-through funding from CSS, we randomly selected three for testing. Our random sample was not, nor intended to be, statistically valid. One of the three subrecipients was not monitored appropriately. Effect – The subrecipient may have findings related to the grant funding provided by CSS which were unknown and not adequately addressed by CSS. Cause – CSS did not have the appropriate controls in place over the subrecipient monitoring process. Repeat finding – No. Recommendation – We recommend CSS revise their procedures to include all subrecipients in their monitoring procedures, obtaining audit reports for all subrecipients to ensure there are no audit findings related to the subaward and issue management decisions for any audit findings that are identified. Views of Responsible Officials – Management agrees with the finding and recommendation.