Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference: 2024-003
NH Department of Military
National Guard Military Operations and Maintenance (O&M) Projects (Assistance Listing #12.401)
Federal Award Number: W012TF0190201001, W012TF023-27-2-1001
Federal Award Year: 2022, 2023, 2024
U.S. Department of Defense
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-002
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
The SF-270, Request for Advance or Reimbursement must be submitted as part of the cash draw request process.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over the SF-270 Request for Advance or Reimbursement report, we identified the following:
A. For 23 of 35 SF-270 reports selected for testwork, we were unable to agree line items a, total program outlays and line-item c, net program outlays, to the supporting documentation provided.
B. For 22 of 35 SF-270 reports selected for testwork, we were unable agree line-item e, total, to the supporting documentation provided.
C. For 22 of 35 SF-270 reports selected for testwork, we were unable agree line-item f, non-federal share of amount online e, to the supporting documentation provided.
D. For 7 of 35 reports selected for testwork, we were unable to agree line-item g, federal share of amount online e, to the supporting documentation provided.
E. For 4 of 35 reports selected for testwork, we were unable to agree line-item h, federal payments previously requested, to the supporting documentation provided.
F. For 4 of 35 reports selected for testwork, we were unable to agree line item i, federal share now requested, to the supporting documentation provided.
G. For all 35 SF-270 reports selected for testwork, we identified that there was a lack of segregation of duties related to the preparation of the SF-270 as there was no documented supervisory review performed over the completeness and accuracy of the reports prior to submission.
Cause
The cause of the condition found was due to insufficient policies and procedures to track total expenditures incurred by appendix for each federal award year. The Department relies on the previous amounts reported on the SF-270 report only and does not readily maintain supporting documentation for each report to reconcile the amounts reported on the SF-270 report to New Hampshire First, the State’s centralized accounting system.
For each federal fiscal year, the Department uses an internal tracking sheet that tracks by appendix the federal share of costs incurred each month. The tracking sheet does not include the state share of expenses if a state match is required. As a result, for several appendices the tracking sheet used by the Department does not reconcile to the SF-270 report.
Effect
The effect of the condition found is SF-270 reports submitted were not complete and accurate.
Questioned Costs: Not determinable.
Recommendation
We recommend that the existing policies and procedures in place to prepare the SF-270 be reviewed and internal controls be implemented that will include an independent supervisory review to ensure that the SF-270 is complete and accurate at the time of submission. This would include ensuring that each line item of the SF-270 properly reconciles to supporting documentation. This documentation should be maintained with each report to substantiate the amounts reported are complete and accurate.
View of Responsible Officials: Management does not concur with this finding.
Rejoinder: As documented within the condition found, for a sample of SF-270 reports selected for testwork, we were unable to agree the amount reported to the supporting documentation provided by the Department. A reconciliation and analysis of expenditures to New Hampshire First, the State of New Hampshire’s centralized accounting system, was not provided by the Department as part of this audit.
Finding Reference Number: 2024-004
NH Department of Military
National Guard Military Operations and Maintenance (O&M) Projects (Assistance Listing #12.401)
Federal Award Number: W012TF0190201001, W012TF023-27-2-1001
Federal Award Year: 2022, 2023, 2024
U.S. Department of Defense
Compliance Requirement: Cash Management
Type of Finding: Material Weakness
Prior Year Finding: 2023-003
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
As part of our testwork over the cash management process, we identified a lack of segregation of duties related to the preparation of the cash request amount and the approval and authorization for the amount to be drawn. During the year ended June 30, 2024, the same individual calculated and authorized each cash draw for the 35 cash draws selected for testwork.
Cause
The cause of the condition found was due to insufficient internal controls to ensure an independent supervisory review is performed over each cash draw request, resulting in a lack of segregation of duties.
Effect
The effect of the condition found is that an error in the cash draw amount calculated could be made and the error would not be identified timely.
Questioned Costs: None.
Recommendation
We recommend that internal controls be implemented that would result in a documented independent review over the amount calculated for the cash draw request to ensure that the amount drawn is complete and accurate.
View of Responsible Officials: Management does not concur with this finding.
Rejoinder: As documented within the condition found the Department does not have sufficient controls in place to ensure the accuracy of the cash draw as there is no supervisory review performed by the Department. The reliance on the federal government to review the accuracy of the cash draw is not a substitute for the Department maintaining its own internal controls.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference: 2024-010
NH Department of Business and Economic Affairs
NH Department of Administrative Services
COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027)
Federal Award Numbers: SLFRP0145
Federal Award Year: 2021
U.S. Department of Treasury
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency
Prior Year Finding: 2023-004
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
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.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over suspension and debarment, we identified that for 4 of 112 items selected for testwork related to 60 contracts and 52 subrecipients, there was no supporting documentation that the State had verified either through a signed certification or searching SAM.gov that the entity was not suspended or debarred. As part of our testwork, we reviewed SAM.gov for each of the 4 items and found that none of the entities had been suspended or debarred. Of the 4 sample selections, all 4 selections were contracts.
Cause
The cause of the condition found is due to insufficient controls and procedures to ensure that for all covered transactions the State determines if the entity covered has been suspended or debarred.
Effect
The effect of the condition found is that the funds could be paid to an entity that has been suspended or debarred and costs paid to the entity would be unallowable.
Questioned Cost: Not determinable.
Recommendation
We recommend that the State review its existing policies and procedures related to suspension and debarment and ensure that all covered transactions with entities are properly reviewed to verify that the entity has not been suspended and debarred.
View of Responsible Officials: Management partially concurs with the finding above.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that the Department ensured that the vendor was not suspended or debarred for 4 of 112 samples selected for testwork.
Finding Reference: 2024-011
NH Governor’s Office of Emergency Relief and Recovery
COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027)
Federal Award Numbers: SLFRP0145
Federal Award Year: 2021
U.S. Department of Treasury
Compliance Requirement: Procurement
Type of Finding: Significant Deficiency
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
An entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor. The pass-through entity is responsible for making case-by-case determinations to determine whether the entity receiving Federal funds is a subrecipient or a contractor. The Federal agency may require the pass-through entity to comply with additional guidance to make these determinations, provided such guidance does not conflict with this section. The Federal agency does not have a direct legal relationship with subrecipients or contractors of any tier; however, the Federal agency is responsible for monitoring the pass-through entity's oversight of first-tier subrecipients. All of the characteristics listed below may not be present in all cases, and some characteristics from both categories may be present at the same time. No single factor or any combination of factors is necessarily determinative. The pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. In making this determination, the substance of the relationship is more important than the form of the agreement (2 CFR 200.331)
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities and third-party contracts to support allowable activities under the federal program. As part of our testwork over the completeness of the procurement (contracts) and subrecipient grants populations, we identified the following:
A. For 91 procurement samples selected for testwork, 12 sample selections did not appear to be contracts. 11 of 12 sample items appeared to be a beneficiary payment. The remaining 1 sample items appeared to be a subrecipient grant agreements.
B. For 2 of 24 subrecipient grant samples selected for testwork, 2 sample selections did not appear to be a subrecipient grant. 1 of the 2 sample selections appeared to be a contract and the other 1 was a forgivable loan payment that appeared to be a beneficiary payment.
No procurement noncompliance was identified for the contract and subrecipient samples subject to testwork.
Cause
The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient versus beneficiary payment in order to determine what additional monitoring procedures the State needs to be perform and to determine if the recipient needs to comply with federal compliance requirements.
.
Effect
The effect of the condition found is that the State may not have properly classified contracts, beneficiary and subrecipient awards.
Questioned Costs: None.
Recommendation
We recommend that the State continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-012
NH Department of Business and Economic Affairs
COVID-19 Capital Projects Fund (Assistance Listing #21.029)
Federal Award Number: CPFFN0143
Federal Award Year: 2022
U.S. Department of Treasury
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-006
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
The Project and Expenditure Report for States, Territories & Freely Associated States (PRA 1505-0277) is required to be filed on a quarterly basis.
For broadband infrastructure projects, miles of fiber purchased is required to be reported.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of our testwork over the Project and Expenditure Report for States, Territories & Freely Associated States, we identified the following:
A. The total amount expended for administrative expenses within Section 6.1 was under reported by $3,427 for the quarter ending September 30, 2023.
B. The actual total miles of fiber deployed, and actual total locations are not tracked by the Department and as a result, we were unable to verify the accuracy of the data reported within section 5.2 for the September 30, 2023 and June 30, 2024 quarterly reports. The Department reported its planned activities only but there were no actual results reported.
Cause
The cause of the condition found related to bullet A was due an existing internal control deficiency related to the review and approval of the report not being at a precision level that would identify the underreporting of expenses incurred that was identified as part of the June 30, 2023 audit. The Department subsequently implemented their corrective action plan, and a similar error was not identified within the June 30, 2024 quarterly report. In addition, as it relates to the number of funded locations and the planned number of miles of fiber to be deployed, the Department relies upon data provided by their contractors to report this data. The Department has made attempts to obtain this information however the data has not been provided by the contractors so that the amounts reported within the quarterly reports can be updated.
Effect
The effect of the condition found is that the quarterly project and expenditures reports were not complete and accurate.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to review its existing internal controls over quarterly reporting to ensure that all line items reported are complete and accurate.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-018
NH Department of Health and Human Services
Immunization Cooperative Agreements and COVID-19 Immunization Cooperative Agreements (Assistance Listing #93.268)
Federal Award Number: NH23IP922595
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of the 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported in the FFATA report as it was not included within the subaward agreement.
C. For all 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 3 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$430,000 N/A $430,000 N/A $30,000
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-018
NH Department of Health and Human Services
Immunization Cooperative Agreements and COVID-19 Immunization Cooperative Agreements (Assistance Listing #93.268)
Federal Award Number: NH23IP922595
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of the 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported in the FFATA report as it was not included within the subaward agreement.
C. For all 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 3 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$430,000 N/A $430,000 N/A $30,000
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-019
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Number: NUK50CK000522
Federal Award Year: 2021, 2022
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2022-010
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Quarterly fiscal reports are required to be submitted beginning 69 days after the notice of Awards is issued.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
Quarterly Reporting
As part of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, the New Hampshire Department of Health and Human Services (the Department) reports financial information to the Centers for Disease Control (CD) on a quarterly basis related to expenditures incurred and the amount of unliquidated obligations for the reporting period. During our testwork over quarterly reporting, we identified that for 12 of 27 quarterly reports selected for testwork, we were unable to obtain a copy of the report summary for the reporting period selected for testwork. As a result, were unable to verify that the that the unliquidated obligation for the reporting period was properly reported.
FFATA Reporting
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 4 FFATA reports selected for testwork, we were unable to validate the UEI number as it was not included within the subaward.
C. For 1 of 4 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 1 N/A 4
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,947,055 N/A $266,603 N/A $1,947,055
Cause
The cause of the condition found related to quarterly reporting is that the Department did not maintain a screenshot of the unliquidated obligations reported for COVID related federal awards. The federal reporting system does not allow the user to review prior submissions and only shows the status of the grant, including the unliquidated obligation balance. The only thing that appears in the federal reporting system is the current status of the grant.
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department does not have sufficient documentation to support the unliquidated obligation balances for COVID related quarterly reports the amounts reported may not have been accurately filed. In addition, the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures related to monthly reporting to ensure that a copy of all quarterly financial reports summary for all COVID grants maintained to properly document that the unliquidated obligation is properly reported.
We further recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA reports prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-019
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Number: NUK50CK000522
Federal Award Year: 2021, 2022
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2022-010
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Quarterly fiscal reports are required to be submitted beginning 69 days after the notice of Awards is issued.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
Quarterly Reporting
As part of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, the New Hampshire Department of Health and Human Services (the Department) reports financial information to the Centers for Disease Control (CD) on a quarterly basis related to expenditures incurred and the amount of unliquidated obligations for the reporting period. During our testwork over quarterly reporting, we identified that for 12 of 27 quarterly reports selected for testwork, we were unable to obtain a copy of the report summary for the reporting period selected for testwork. As a result, were unable to verify that the that the unliquidated obligation for the reporting period was properly reported.
FFATA Reporting
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 4 FFATA reports selected for testwork, we were unable to validate the UEI number as it was not included within the subaward.
C. For 1 of 4 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 1 N/A 4
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,947,055 N/A $266,603 N/A $1,947,055
Cause
The cause of the condition found related to quarterly reporting is that the Department did not maintain a screenshot of the unliquidated obligations reported for COVID related federal awards. The federal reporting system does not allow the user to review prior submissions and only shows the status of the grant, including the unliquidated obligation balance. The only thing that appears in the federal reporting system is the current status of the grant.
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department does not have sufficient documentation to support the unliquidated obligation balances for COVID related quarterly reports the amounts reported may not have been accurately filed. In addition, the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures related to monthly reporting to ensure that a copy of all quarterly financial reports summary for all COVID grants maintained to properly document that the unliquidated obligation is properly reported.
We further recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA reports prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-020
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Numbers: NUK50CK000522
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-011
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient.
B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-020
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Numbers: NUK50CK000522
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-011
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient.
B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-021
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-015
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity must:
• Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a);
• Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521.
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2024, $38,545,693 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following:
A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 4 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated:
a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414)
b. Identification of whether the award is R&D
B. The data that is used to compile the Annual Report on Households Assisted by LIHEAP is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate.
Cause
The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that award information is appropriately communicated and that there is appropriate monitoring procedures performed over the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports.
Effect
The effect of the condition found is that the Department did not comply with section 2 CFR 200.332 (a) and 2 CFR 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that all required award identification information is communicated to subrecipients and over the monitoring of data submitted by subrecipients to be used in the Annual Report on Households Assisted by LIHEAP to ensure that the report is complete and accurate.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-022
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-016
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Annual Report on Households Assisted by LIHEAP (OMB No. 0970-0060) – As part of the application for block grant funds each year, a report is required for the preceding fiscal year of (1) the number and income levels of the households assisted for each component and any type of LHEAP assistance (heating, cooling, crisis, and weatherization); and (2) the number of households served that contained young children, elderly, or persons with disabilities, or any vulnerable household for each component. Territories with annual allotments of less than $200,000 and all Native American tribes are required to report only on the number of households served for each program component (42 USC 8629; 45 CFR section 96.82).
Quarterly Performance and Management Report (OMB No. 0970-0589) https://omb.report/icr/202205-0970-017/doc/121847100 – Grant recipients must submit data and information about LIHEAP during the current FY, including success, challenges, needs and innovations. The quarterly reports focus on assisted households, performance management, obligation of funding, changes made due to anticipated increase in energy bills, collaboration with other utility programs, and training and technical assistance needs.
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over federal reporting as part of the Low-Income Home Energy Assistance program (LIHEAP), we noted the following:
A. During our testwork over FFATA report completed by the New Hampshire Department of Energy (the Department), we identified that for 1 of 3 FFATA reports selected for testwork that the FFATA report was not submitted timely.
Reports Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
4 0 1 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$86,991,138 $0 $26,928,592 $0 $0
B. The Annual Report on Households Assisted by LIHEAP report was submitted by the Department’s externally engaged consultants, APPRISE, for both program year ending September 30, 2023 and September 30, 2024. For this process, the Department submitted raw data files retrieved from their subrecipients to APPRISE to utilize in the development of the balances submitted within the report. The Department was unable to provide us with supporting documentation that reconciled to the balances submitted within the report, as the balances submitted were developed by APPRISE. As they were unable to provide us with supporting documentation behind the balances submitted, we were unable to determine the report submitted was complete and accurate. We further identified that for the report submitted for program year September 30, 2024, the report was required be resubmitted due to an error being discovered by APPRISE after their submission of the report.
C. During our testwork related to the Quarterly Performance and Management Reports, we identified the following:
a. For 1 of 4 quarterly reports tested, we were unable to determine whether the report was submitted as the report provided was not signed and dated by the Program Director.
b. For the Quarterly Performance and Management report submitted for the quarters ended September 30, 2023 and December 31, 2023, we were unable to verify to obtain documentation to support the following key line items:
i. Number of assisted households during the same period last year for the same quarter x for federal fiscal year 2023,
ii. Total amount of funds obligated for LIHEAP fiscal year 2023 allotment
iii. Amount of funds obligated for other supplemental allotment.
Cause
The cause of the condition found related primarily to insufficient resources to ensure reports are filed and complete and accurate. In addition, the Department did not have procedures in place to ensure it reconciled reports prepared by their contractor to ensure that the reports were accurately filed.
Effect
The effect of the condition found is that the required reports may not be submitted and accurate and their are sufficient internal controls to identify errors or non-submission.
Questioned Costs: None.
Recommendation
We recommend that the Department should review to ensure there is sufficient safeguards in place for professionals to perform when positions are vacant so that necessary processes are completed related to compliance with federal requirements, including submission of federal reports, including FFATA reports. In addition, we recommend that the Department implement written policies and procedures for the compilation and review of the Quarterly Performance and Management Report and Annual Report on Households Assisted by LIHEAP and ensure that the documentation to support the amounts reported is maintained to support that the report is complete and accurate.
View of Responsible Official: Management concurs with the finding above.
Finding Reference Number: 2024-023
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Cash Management
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-014
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over federal reporting as part of the Low-Income Home Energy Assistance program (LIHEAP), we noted the New Hampshire Department of Energy (the Department) advances payments to subrecipients to ensure that they have sufficient cash on hand in order to pay for benefit payments. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $38,545,693 to subrecipients during the year ended June 30, 2024. During our testwork over cash management, we noted that for the 4 cash advance payment samples selected for testwork, while the Department properly tracks subrecipient's expenditures, the Department does not ensure that the amount of time the cash on hand is minimized. The engagement team noted that for all 4 samples tested, cash is on hand for over 30 days according to each tracking sheet maintained by management.
Cause
The cause of the condition found was primarily due to insufficient monitoring procedures and internal controls to ensure that subrecipients either utilized advanced funds timely or effectively evaluate the amount of funds the subrecipient would need to have on hand at the time of the advance payment.
Effect
The effect of the condition found is that the Department was not in compliance with 2 CFR section 200.204(b)(1).
Questioned Costs: None.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-026
NH Department of Health and Human Services
Opioid STR (Assistance Listing #93.788)
Federal Award Number: H79TI081685, H79TI083326, H79TI085759
Federal Award Year: 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements –Clearly identify to the subrecipient the award as a subrecipient by providing the information prescribed in 2 CFR 200.332(a)
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $21,190,358 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 3 of 7 subrecipients selected for testwork, per review of the award communication, the Department did not properly communicate the indirect cost rate for the federal award.
B. For 1 of 7 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. We noted that while there no monitoring procedures listed, the Department did complete a monthly expenditure detail review.
C. For 1 of 7 subrecipients selected for testwork, the risk assessment indicated that an annual onsite monitoring review was to be conducted. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that the required award identification information is communicated to all subrecipients and to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management partially concurs with the finding above.
Rejoinder: As documented in Bullet B above, the risk assessment provided by the Department for 1 of 7 subrecipients did not contain any suggested monitoring procedures. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
Finding Reference Number: 2024-027
NH Department of Health and Human Services
Opioid STR (Assistance Listing #93.778)
Federal Award Number: H79TI081685, H79TI083326, H79TI085759
Federal Award Year: 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following that for all 7 FFATA reports selected for testwork, there was no evidence that the reports were reviewed and approved prior to submission. While there was no evidence of review, the reports appeared to be complete, accurate and filed timely.
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-028
NH Department of Health and Human Services
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01
Federal Award Year: 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-017
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-028
NH Department of Health and Human Services
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01
Federal Award Year: 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-017
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-029
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08T083509, 1B08T1084595, 1B08T1083464, 6B08T103464, 1B08T1084659, B08T108521
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 3 of 4 FFATA reports selected for testwork, we were unable to validate the UEI number was not included within the subaward agreement.
C. For 3 of 4 FFATA reports, the reports were not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 3 2 3
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,545,840 N/A $6,788,363 $5,442,523 $1,345,840
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-029
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08T083509, 1B08T1084595, 1B08T1083464, 6B08T103464, 1B08T1084659, B08T108521
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 3 of 4 FFATA reports selected for testwork, we were unable to validate the UEI number was not included within the subaward agreement.
C. For 3 of 4 FFATA reports, the reports were not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 3 2 3
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,545,840 N/A $6,788,363 $5,442,523 $1,345,840
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-030
NH Department of Education
Disability Insurance/SSI Cluster (Assistance Listing #96.001)
Federal Award Numbers: 2304NHDI00, 2404NHD100
Federal Award Year: 2023, 2024
U.S. Social Security Administration
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-019
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
The SSA-4513 – State Agency Report of Obligations for SSA Disability Programs – is due quarterly for each fiscal year still open in order to account for program disbursements and unliquidated obligations (POMS DI 39506.202).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting related to the SSA-4513 quarterly report, we identified the following:
A. For all 4 of 9 SSA-4513 reports selected for testwork, line item 7 was not checked to identify if the SSA-871 needed to be attached to the report. It is unclear if this needed to be attached or not.
B. For all 9 SSA-4513 reports selected for testwork, the reports did not reconcile to the internal tracking sheets provided to validate the amounts reported. For all reports there were variances between the tracking sheets and the dollar amounts included within the federal report within sections 1, 2, 3 and 4. While variances are identified, we noted that the variances were not material overall to the individual line item.
C. For all 9 SSA-4513 reports selected for testwork, we were unable to validate the completeness and accuracy of the amounts reported within Section 1 for Columns (A) for Disbursements, (B) for unliquidated obligations and (C) total obligations for line items 1, 2, 3 and 4. As such, we are not able to validate that the amounts reported are complete and accurate. As we were not able to obtain documentation to validate the obligation balances, we are unable to validate the accuracy of amounts reported within Sections 1, 2, and 3 of the report.
D. For all 9 of the SSA-4513 reports selected for testwork, there was no support for the difference between the total obligations and cumulative obligational authorization.
E. For 1 of 9 SSA-4513 reports selected for testwork, no supporting documentation was provided.
F. For 8 of 9 SSA-4513 reports selected for testwork, documentation was not provided for Line Item 2.d, Other Identity obligation & amount
Cause
The cause of the condition found related to the SSA-4513 was due to insufficient policies and procedures to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed. Based on the documentation that was provided to support the data reported within each quarterly report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is the SSA-4134 reports were not complete and accurate when they were filed.
Questioned Costs: None.
Recommendation
We recommend that the existing policies and procedures be developed to ensure that all documentation to support the amounts reported on the SSA-4513 is properly maintained for each quarterly report. In addition, internal control procedures should be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documenting showing that the required review process was performed prior to submitting the SSA-4513.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-031
NH Department of Education
Disability Insurance/SSI Cluster (Assistance Listing #96.001)
Federal Award Numbers: 2304NHDI00, 2404NHD100
Federal Award Year: 2023, 2024
U.S. Social Security Administration
Compliance Requirement: Special Tests and Provisions – Qualified Providers
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-020
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Each state agency is responsible for comprehensive oversight management of its process and for ensuring accuracy, integrity, and economy of its processes (20 CFR sections 404.519g and 416.919g, and POMS DI 396569.300). As part of these duties, DDSs must have and follow procedures for performing medical license verifications to ensure that only qualified providers perform DDSs tasks. By “qualified,” SSA means that the medical source must:
1. Be currently licensed in the state and have the training and experience to perform the type of examination or tests DDS requests; and
2. Not be barred from participating in Medicare or Medicaid programs or other federal or federally assisted programs (20 CFR sections 404.5159g and 416.919g). Prior to using the services of any medical provider, the DDS must check the System of Award Management (SAM) website.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over the special test and provision related to qualified providers, we identified the following 9 of 9 exceptions:
A. For 2 of the 9 new providers selected for testwork, there was no documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for new providers and no information was provided to support the provider had a valid medical license.
B. For 3 of the 9 new providers selected for testwork, there was no documentation maintained to support the start date of the individual to verify the inspection of the SAM.gov website was performed prior to use of the provider’s service.
C. For the remaining 4 of the 9 new providers selected for testwork, the supporting documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for the provider occurred subsequent to the individual’s start date.
Cause
The cause of the condition found is primarily due to insufficient policies and procedures to verify a provider’s had a valid medical license or the provider’s suspension and debarment status had been reviewed within SAM.gov prior to use of services by the provider as required by the federal regulations. In response to the prior year finding corrective actions were being implemented after June 30, 2024 and not all personnel were following the policies and procedures. There does not appear to be sufficient internal controls in place to ensure that reviews of provider’s licenses and suspension and debarment status are performed, completed and properly documented and sufficient documentation is maintained and reviewed.
Effect
The effect of the condition found is that documentation to support the qualifications of providers has not been appropriately maintained and providers could have been used that did not meet the criteria to be a qualified provider.
Questioned Costs: Not determinable.
Recommendation
We recommend that written policies and procedures be developed and followed by all personnel to outline what the required procedures are related to reviewing professional licenses and suspension and debarment status for new provider. The policies should describe how the reviews will be performed, how the review will be documented, and the timing of when reviews will be performed relative to the provider’s start date. Internal controls should be implemented to ensure that an appropriate review over the review is conducted to ensure that the review is performed, completed and accurate documentation maintained.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR
Federal Award Year: July 29-30, 2021, July 1-2, 2017
U.S. Department of Homeland Security
Compliance Requirement: Special Tests and Provisions - Project Accounting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-021
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following:
A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to.
B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided.
Cause
This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation.
Effect
The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a).
Questioned Costs: None.
Recommendation
We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR
Federal Award Year: July 29-30, 2021, July 1-2, 2017
U.S. Department of Homeland Security
Compliance Requirement: Special Tests and Provisions - Project Accounting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-021
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following:
A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to.
B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided.
Cause
This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation.
Effect
The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a).
Questioned Costs: None.
Recommendation
We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024
U.S. Department of Homeland Security
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following:
A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely.
B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported.
C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
8 1 10 Unknown Unknown
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,616,072 $919,070 Unknown Unknown Unknown
Cause
The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate.
Effect
The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024
U.S. Department of Homeland Security
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following:
A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely.
B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported.
C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
8 1 10 Unknown Unknown
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,616,072 $919,070 Unknown Unknown Unknown
Cause
The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate.
Effect
The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020
U.S. Department of Homeland Security
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-023
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following:
A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated:
• Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and
• Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork
B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures.
C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely.
D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted:
• For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year.
• For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report.
Cause
The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures.
Questioned Costs: None.
Recommendation
We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h).
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020
U.S. Department of Homeland Security
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-023
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following:
A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated:
• Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and
• Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork
B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures.
C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely.
D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted:
• For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year.
• For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report.
Cause
The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures.
Questioned Costs: None.
Recommendation
We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h).
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-002
NH Department of Education
Child Nutrition Cluster (Assistance Listing #10.553, #10.555, #10.556, #10.559)
Federal Award Numbers: 244NH304N1099, 244NH304N1199
Federal Award Year: 2023, 2024
U.S. Department of Agriculture
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement.
2 CFR Part 170 “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $40,468,041 in Child Nutrition Cluster Grants (CNC Grant) to Local Educational Agencies (LEAs).
During our testwork, we noted that the Department did not submit FFATA reports for all subawards. The following noncompliance was noted for the sample selected:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
40 40 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not
timely Subaward amount incorrect Subaward incorrect key elements
$ 584,546 $ 584,546 $0 $0 $0
Cause
The Department came to a determination that the FFATA reporting did not apply to the first-tier subawards provided to the LEAs under the child nutrition program.
Effect
The condition found that first-tier subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System.
Questioned Costs: None.
Recommendation
We recommend DOE implement a process and internal controls to ensure that all first-tier subawards of $30,000 or more be reported in accordance with the Federal Funding Accountability and Transparency Act.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference: 2024-003
NH Department of Military
National Guard Military Operations and Maintenance (O&M) Projects (Assistance Listing #12.401)
Federal Award Number: W012TF0190201001, W012TF023-27-2-1001
Federal Award Year: 2022, 2023, 2024
U.S. Department of Defense
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-002
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
The SF-270, Request for Advance or Reimbursement must be submitted as part of the cash draw request process.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over the SF-270 Request for Advance or Reimbursement report, we identified the following:
A. For 23 of 35 SF-270 reports selected for testwork, we were unable to agree line items a, total program outlays and line-item c, net program outlays, to the supporting documentation provided.
B. For 22 of 35 SF-270 reports selected for testwork, we were unable agree line-item e, total, to the supporting documentation provided.
C. For 22 of 35 SF-270 reports selected for testwork, we were unable agree line-item f, non-federal share of amount online e, to the supporting documentation provided.
D. For 7 of 35 reports selected for testwork, we were unable to agree line-item g, federal share of amount online e, to the supporting documentation provided.
E. For 4 of 35 reports selected for testwork, we were unable to agree line-item h, federal payments previously requested, to the supporting documentation provided.
F. For 4 of 35 reports selected for testwork, we were unable to agree line item i, federal share now requested, to the supporting documentation provided.
G. For all 35 SF-270 reports selected for testwork, we identified that there was a lack of segregation of duties related to the preparation of the SF-270 as there was no documented supervisory review performed over the completeness and accuracy of the reports prior to submission.
Cause
The cause of the condition found was due to insufficient policies and procedures to track total expenditures incurred by appendix for each federal award year. The Department relies on the previous amounts reported on the SF-270 report only and does not readily maintain supporting documentation for each report to reconcile the amounts reported on the SF-270 report to New Hampshire First, the State’s centralized accounting system.
For each federal fiscal year, the Department uses an internal tracking sheet that tracks by appendix the federal share of costs incurred each month. The tracking sheet does not include the state share of expenses if a state match is required. As a result, for several appendices the tracking sheet used by the Department does not reconcile to the SF-270 report.
Effect
The effect of the condition found is SF-270 reports submitted were not complete and accurate.
Questioned Costs: Not determinable.
Recommendation
We recommend that the existing policies and procedures in place to prepare the SF-270 be reviewed and internal controls be implemented that will include an independent supervisory review to ensure that the SF-270 is complete and accurate at the time of submission. This would include ensuring that each line item of the SF-270 properly reconciles to supporting documentation. This documentation should be maintained with each report to substantiate the amounts reported are complete and accurate.
View of Responsible Officials: Management does not concur with this finding.
Rejoinder: As documented within the condition found, for a sample of SF-270 reports selected for testwork, we were unable to agree the amount reported to the supporting documentation provided by the Department. A reconciliation and analysis of expenditures to New Hampshire First, the State of New Hampshire’s centralized accounting system, was not provided by the Department as part of this audit.
Finding Reference Number: 2024-004
NH Department of Military
National Guard Military Operations and Maintenance (O&M) Projects (Assistance Listing #12.401)
Federal Award Number: W012TF0190201001, W012TF023-27-2-1001
Federal Award Year: 2022, 2023, 2024
U.S. Department of Defense
Compliance Requirement: Cash Management
Type of Finding: Material Weakness
Prior Year Finding: 2023-003
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
As part of our testwork over the cash management process, we identified a lack of segregation of duties related to the preparation of the cash request amount and the approval and authorization for the amount to be drawn. During the year ended June 30, 2024, the same individual calculated and authorized each cash draw for the 35 cash draws selected for testwork.
Cause
The cause of the condition found was due to insufficient internal controls to ensure an independent supervisory review is performed over each cash draw request, resulting in a lack of segregation of duties.
Effect
The effect of the condition found is that an error in the cash draw amount calculated could be made and the error would not be identified timely.
Questioned Costs: None.
Recommendation
We recommend that internal controls be implemented that would result in a documented independent review over the amount calculated for the cash draw request to ensure that the amount drawn is complete and accurate.
View of Responsible Officials: Management does not concur with this finding.
Rejoinder: As documented within the condition found the Department does not have sufficient controls in place to ensure the accuracy of the cash draw as there is no supervisory review performed by the Department. The reliance on the federal government to review the accuracy of the cash draw is not a substitute for the Department maintaining its own internal controls.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-005
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02
Federal Award Year: 2022, 2023
U.S. Department of Interior
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. This would include internal controls related to the cash management process.
Condition
During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following:
A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated:
• Subrecipient's unique entity identifier
• Identification of whether the Federal award is for research and development
B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following:
• For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed.
• For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire.
As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment.
C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement.
D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report.
As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project.
E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued.
Cause
The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-006
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F19AF00556-01, F21AF04030-06, F22AF03670-01
Federal Award Year: 2019, 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: SEFA Reporting
Type of Finding: Material Weakness and Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR section 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.510(b) states the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
The New Hampshire Fish and Game Department (the Department) oversees 25 different grants funded under the Fish and Wildlife Cluster (the Program). To assist in the management of the grants, the Department uses QuickBooks as their main system of books and records, rather than the State of New Hampshire’s centralized accounting system, NH First. The Department manually enters expenditure transactional data into QuickBooks and heavily relies on a number of excel tracking sheets to track expenditures, cash draws, and in-kind match earned for each of the 25 grants. During our testwork over the Program, we identified the following:
A. For 2 of 25 grants, we identified that there were out of period costs that were included on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024. Specifically we identified the following:
a. For 1 of the 2 grants, the Department, included $247,562 of the expenditures that were paid between March 17, 2017 and January 13, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
b. For the other 1 of 2 grants, the Department included $761 of expenditures that were paid on February 10, 2023 and should not have been reported on the June 30, 2024 SEFA, resulting in an overstatement of expenditures.
B. For 1 of 25 grants, the Department reported on the SEFA the amount reimbursed through the cash draw process as of June 30, 2024 rather than expenditures paid during that same period. As such, the amount reported on the June 30, 2024 SEFA was understated by $14,830.
C. For 1 of 25 grants, we were unable to reconcile the amount reported on the SEFA. For the grant, the Department included $2,637,617 of expenditures on the June 30, 2024 SEFA. As part of our review of the expenditures reported, we were unable to recalculate the amount included by the Department. Based upon the total expenditures incurred during the period ending June 30, 2024, it appeared that the amount that should have been reported was $2,755,548. As such, it appeared that the June 30 2024 was understated by $117,931.
D. For 5 of 5 grants that reported subrecipient pass through expenditures, it appeared that the Department reported pass-through expenditures on the SEFA that included both the state and federal share of the costs, resulting in the pass-through amount being overstated by $118,195.
Cause
The cause of the condition found appears to be related to the heavy reliance on manual spreadsheets and QuickBooks. The manual data entry into QuickBooks and the use of spreadsheets are susceptible to human error. As the Department does not have any internal controls in place to ensure the spreadsheets or QuickBooks reconcile to NH First, if there was an error in the data used by the Department, it would be difficult to detect.
In addition, the Department incorrectly included prior period costs on the SEFA as it had been believed that since the costs had not previously been reported but were eligible for reimbursement should be included on the June 30, 2024 SEFA.
Effect
The effect of the condition found is that the expenditures and subrecipient pass through amounts were not accurately presented on the SEFA.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls to ensure all spreadsheets utilized to manage the program reconcile to QuickBooks and that QuickBooks reconciles to NH first on a routine basis. The Department should also implement internal controls to evaluate the amounts reported on the SEFA to ensure that only current period expenditures that are eligible for reimbursement are reported on the SEFA.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that supported a reconciliation between QuickBooks and New Hampshire First was performed. The amounts reported on the SEFA by the Department for this program were not complete and accurate.
Finding Reference Number: 2024-007
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF02312-00, F21AF04100-02, F22AF02844-00, F24AF00586-00, F23AF02720-00, F21AF03886-03, F20AF11939-04, F23AF02954-00, F23AF02609-00, F23AF02714-01, F19AF00556-01, F19AF00556-01, F22AF03670-01, F19AF00556-01, F22AF02616-02, F22AF00514-01, F19AF00556-01, F21AF04030-06
Federal Award Year: 2019, 2020 2021, 2022, 2023, 2024
U.S. Department of Interior
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Per Part 3 of the Compliance Supplement, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity in order to be allowable under federal awards.
Further per 2 CFR section 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over Activities Allowed or Unallowed/Allowable Costs/Costs Principles, we identified the following:
A. For 18 of 25 payroll and fringe benefit costs selected for testwork, we were unable to agree the payroll and fringe benefit costs charged to the Fish and Wildlife Cluster (the program) to the State of New Hampshire’s centralized accounting system, NH First. The New Hampshire Department of Fish and Game (the Department) does not charge payroll and fringe benefit costs incurred by the program as processed in NH First. Instead, the Department utilizes an internally calculated "federal rate" that is used to charge both payroll and fringe benefit costs based upon the number of hours worked to the program. As described by the Department, the federal rate is calculated based upon an employee's fringe benefits, the approved NH First pay rate, and the employee’s years of service. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 20 samples selected testwork as recorded in NH First, we were not able to reconcile this amount to what the Department actually charged the program. A variance of $9,754 was identified and included in the Questioned Cost amount below.
B. For 5 of 25 payroll costs selected for testwork, we were unable to obtain support to substantiate the payroll costs recorded by the Department, including the Fish and Game Activity Task Report, which shows the Department's method of allocating time and payroll to the Cluster. As a result, we were unable to reconcile the amount paid in NH First of $11,541 to what the Department had allocated to the program. While we were able to recalculate the employee’s payroll and fringe benefit amounts for each of the 5 samples selected based upon what was recorded in NH First, we were not able to reconcile this amount to what the Department had actually charged the program. Since we were unable to determine what was charged to the program this amount is not a known questioned cost below.
C. Indirect costs charged to the program are based upon the Department's "federal rate" calculation of payroll and fringe benefit costs as described above in Bullet A. As a result, we were unable to substantiate the basis upon which the indirect cost rate was applied for all 25 payroll periods for testwork. We further noted that for 2 of 25 payroll periods selected for testwork, the indirect costs drawn down at the time of grant close out in proportion to the payroll drawn down exceeded the 18.19% indirect cost rate that should be applied to payroll. A variance of $1,655 was identified and included in the Questioned Cost amount below.
D. During our testwork over the allowability of non-payroll costs, we identified that for 2 of 60 invoices selected for testwork, the invoice was not approved by the Division Chief prior to payment as required. Of the 2 invoices, 1 invoice was approved by the program supervisor and 1 invoice did not contain any evidence of it being approved. While the invoices did not appear to be properly reviewed, the amount paid appeared to be properly supported and as such, no questioned costs were identified.
Cause
The cause of the condition found is that the Department does not utilize the NH First system as the basis to charge payroll, fringe and indirect costs to the program. As described in the condition found above, the Department performs its own calculation of what the payroll and fringe benefit costs are based upon the Department’s calculated federal rate and then subsequently data enters their calculated expenditure information into QuickBooks. The Department uses QuickBooks to track all federal expenditures under the program by individual federal grant. The Department does not perform any reconciliations to ensure what was entered into QuickBooks reconciles to the NH First system in order to verify that the data in QuickBooks is complete and accurate.
In addition, the cause of the condition found related to the review and approval of non-payroll costs is primarily a result of insufficient internal controls in place to ensure all invoices are reviewed and approved prior to payment.
Effect
The effect of the condition found is that the Department would be unable to detect an error within the amounts data entered into QuickBooks and the amount allocated to the program could be inaccurate. In addition, insufficient review and approval of non-payroll expenditures could result in unallowable costs charged to the program.
Questioned Costs: $11,409
Recommendation
We recommend that the Department develop written policies and procedures that outline how payroll and fringe benefit costs are charged to the program and implement controls to ensure the amount of payroll and fringe benefits entered into QuickBooks properly reconciles to NH First as part of its routine payroll process. We also recommend that the Department implement internal controls to ensure that the correct indirect cost rate is utilized based upon the applicable time period for which indirect costs are being calculated. Finally, we recommend that the Department review its existing policies and procedures related to the review and approval of non-payroll expenditures to ensure that they are properly reviewed and approved prior to payment.
View of Responsible Officials: Management partially concurs with this finding.
Rejoinder: As documented within the condition found, the Department did not provide documentation to support that QuickBooks is reconciled to New Hampshire First to ensure that the data within QuickBooks is complete and accurate. Within Bullets B and C were unable to obtain documentation to support these transactions from the Department within a timely manner. As a result of our audit procedures, we identified questioned costs of $11,409.
We further note that the NH First system does allow for the allocation of employee salaries to grants from the standard or normal accounting assignment of their costs. The Department has elected not to implement this model.
Finding Reference Number: 2024-008
NH Fish and Game Department
Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626)
Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02, F21AF04100-02, F21AF03886-03
Federal Award Year: 2021, 2022, 2023
U.S. Department of Interior
Compliance Requirement: Matching
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
In-kind match requirement is to test records to corroborate the values placed on in-kind contributions (including third party in-kind contributions) are in accordance with 2 CFR 200.306, 200.434, and 200.414, and the terms and conditions of the award.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
To meet the federal match required under the program, the New Hampshire Fish and Game Department (the Department) utilizes in-kind match that is earned from volunteer hours and costs contributed by its third party subrecipient. During our testwork over in-kind match, we identified the following:
A. For 7 of 9 subrecipient invoices selected for testwork used to support the Department’s in-kind match, we were unable to obtain documentation to support the amount of the in-kind match earned. For each of the 7 sample selections, the value of the in-kind contribution was handwritten on the subrecipient's invoice for unrelated services. There was no documentation obtained to support the accuracy of this handwritten amount. Upon inquiry, the Department confirmed that no further verification was performed to ensure the subrecipient's in-kind match was accurate and based upon costs in support of the grant associated with the in-kind match.
B. For 1 of 4 volunteer in-kind match contribution calculations, the Department incorrectly allocated volunteer hours using the prior fiscal year rates, resulting in an excess of in-kind match being recorded as earned. In addition, we were unable to verify the existence of 1 of the volunteer timesheets used in this calculation for this sample selection.
Cause
The cause of the condition found is primarily due to insufficient internal controls to ensure that the value of the match contributed by its subrecipient is complete and accurate. Due to the long-standing and collaborative relationship between the Department and the subrecipient, the Department has not developed or implemented formalized policies and procedures related to validating the existence of in-kind match earned.
Further, related to the volunteer hours, the cause of the condition is due to human error. With over 250 timesheets to process, the volume of data and calculations are susceptible to error.
Effect
The effect of the condition found is that the Department did not have appropriate documentation to support the in-kind match earned and applied against its federal award in support of federal funds that were drawn. This could lead to unallowable costs being charged to the grant if the sufficient match was not made.
Questioned Costs: $201,250
Recommendation
We recommend that the Department implement written policies and procedures surrounding the tracking of in-kind match. Internal controls should be implemented to ensure the accuracy of the in-kind match earned, including ensuring that there is supporting documentation to substantiate the amount earned. The existing policies and procedures should also be enhanced related to volunteer time to monitor to ensure that all required timesheets are completed before using the volunteer time in support of its matching requirement and that the appropriate rate is used when determining the value of the volunteer in-kind match.
View of Responsible Officials: Management concurs with this finding except for the questioned cost amount.
Rejoinder: As documented within the condition found, we were unable to obtain sufficient documentation to support in-kind matching costs. As a result of our audit procedures, we identified questioned costs of $201,250.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-009
NH Department of Business and Economic Affairs
WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278)
Federal Award Numbers: AA-3633-21-55-A-33, AA-38543-22-A-33, 23A55AW000046-01, 23A55AT000041-01-01, 23A55AY000021-01-00, 23R55MS000053-01-01, 23A60AD000082-01-00, 24A55AY000058-01-00
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Labor
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: No
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting, we identified that the Department of Business and Economic Affairs (the Department) did not file any reports in accordance with the Federal Financial Accountability and Transparency Act (FFATA) for the year ended June 30, 2024.
Cause
The cause of the condition found was primarily due to staffing changes within the Department. While the Department has a policy regarding FFATA reporting, there appears to be insufficient controls in place to ensure that the required FFATA reports were filed.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures and implement include internal ensure all FFATA reports are submitted in compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference: 2024-010
NH Department of Business and Economic Affairs
NH Department of Administrative Services
COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027)
Federal Award Numbers: SLFRP0145
Federal Award Year: 2021
U.S. Department of Treasury
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency
Prior Year Finding: 2023-004
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
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.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over suspension and debarment, we identified that for 4 of 112 items selected for testwork related to 60 contracts and 52 subrecipients, there was no supporting documentation that the State had verified either through a signed certification or searching SAM.gov that the entity was not suspended or debarred. As part of our testwork, we reviewed SAM.gov for each of the 4 items and found that none of the entities had been suspended or debarred. Of the 4 sample selections, all 4 selections were contracts.
Cause
The cause of the condition found is due to insufficient controls and procedures to ensure that for all covered transactions the State determines if the entity covered has been suspended or debarred.
Effect
The effect of the condition found is that the funds could be paid to an entity that has been suspended or debarred and costs paid to the entity would be unallowable.
Questioned Cost: Not determinable.
Recommendation
We recommend that the State review its existing policies and procedures related to suspension and debarment and ensure that all covered transactions with entities are properly reviewed to verify that the entity has not been suspended and debarred.
View of Responsible Officials: Management partially concurs with the finding above.
Rejoinder: As documented within the condition found, we were unable to obtain documentation that the Department ensured that the vendor was not suspended or debarred for 4 of 112 samples selected for testwork.
Finding Reference: 2024-011
NH Governor’s Office of Emergency Relief and Recovery
COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027)
Federal Award Numbers: SLFRP0145
Federal Award Year: 2021
U.S. Department of Treasury
Compliance Requirement: Procurement
Type of Finding: Significant Deficiency
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
An entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor. The pass-through entity is responsible for making case-by-case determinations to determine whether the entity receiving Federal funds is a subrecipient or a contractor. The Federal agency may require the pass-through entity to comply with additional guidance to make these determinations, provided such guidance does not conflict with this section. The Federal agency does not have a direct legal relationship with subrecipients or contractors of any tier; however, the Federal agency is responsible for monitoring the pass-through entity's oversight of first-tier subrecipients. All of the characteristics listed below may not be present in all cases, and some characteristics from both categories may be present at the same time. No single factor or any combination of factors is necessarily determinative. The pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. In making this determination, the substance of the relationship is more important than the form of the agreement (2 CFR 200.331)
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities and third-party contracts to support allowable activities under the federal program. As part of our testwork over the completeness of the procurement (contracts) and subrecipient grants populations, we identified the following:
A. For 91 procurement samples selected for testwork, 12 sample selections did not appear to be contracts. 11 of 12 sample items appeared to be a beneficiary payment. The remaining 1 sample items appeared to be a subrecipient grant agreements.
B. For 2 of 24 subrecipient grant samples selected for testwork, 2 sample selections did not appear to be a subrecipient grant. 1 of the 2 sample selections appeared to be a contract and the other 1 was a forgivable loan payment that appeared to be a beneficiary payment.
No procurement noncompliance was identified for the contract and subrecipient samples subject to testwork.
Cause
The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient versus beneficiary payment in order to determine what additional monitoring procedures the State needs to be perform and to determine if the recipient needs to comply with federal compliance requirements.
.
Effect
The effect of the condition found is that the State may not have properly classified contracts, beneficiary and subrecipient awards.
Questioned Costs: None.
Recommendation
We recommend that the State continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-012
NH Department of Business and Economic Affairs
COVID-19 Capital Projects Fund (Assistance Listing #21.029)
Federal Award Number: CPFFN0143
Federal Award Year: 2022
U.S. Department of Treasury
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-006
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
The Project and Expenditure Report for States, Territories & Freely Associated States (PRA 1505-0277) is required to be filed on a quarterly basis.
For broadband infrastructure projects, miles of fiber purchased is required to be reported.
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of our testwork over the Project and Expenditure Report for States, Territories & Freely Associated States, we identified the following:
A. The total amount expended for administrative expenses within Section 6.1 was under reported by $3,427 for the quarter ending September 30, 2023.
B. The actual total miles of fiber deployed, and actual total locations are not tracked by the Department and as a result, we were unable to verify the accuracy of the data reported within section 5.2 for the September 30, 2023 and June 30, 2024 quarterly reports. The Department reported its planned activities only but there were no actual results reported.
Cause
The cause of the condition found related to bullet A was due an existing internal control deficiency related to the review and approval of the report not being at a precision level that would identify the underreporting of expenses incurred that was identified as part of the June 30, 2023 audit. The Department subsequently implemented their corrective action plan, and a similar error was not identified within the June 30, 2024 quarterly report. In addition, as it relates to the number of funded locations and the planned number of miles of fiber to be deployed, the Department relies upon data provided by their contractors to report this data. The Department has made attempts to obtain this information however the data has not been provided by the contractors so that the amounts reported within the quarterly reports can be updated.
Effect
The effect of the condition found is that the quarterly project and expenditures reports were not complete and accurate.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to review its existing internal controls over quarterly reporting to ensure that all line items reported are complete and accurate.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-013
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Fund Grants (ESF Grant) to Local Educational Agencies (Local Educational Agencies).
During our testwork over FFATA reporting at the Department for ESF Grants, we selected 60 out of 394 FFATA reports across 198 different LEAs for testing and noted the following:
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
60 0 34 8 25
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$99,319,258 $0 $56,002,866 $6,036,865 $41,275,186
Summary – By Year
Year
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward incorrect key elements
FY21 Count 24 0 9 6 21
FY21 $ $39,289,343 $0 $5,233,893 $4,036,411 $38,341,157
FY22 Count 22 0 22 1 0
FY22 $ $48,539,951 $0 $48,539,951 $124,222 $0
FY23 Count 9 0 3 0 1
FY23 $ $8,090,618 $0 $2,229,022 $0 $286,401
FY24 Count 5 0 0 1 3
FY24 $ $3,399,346 $0 $0 $1,876,232 $2,647,628
Cause
The reconciliation control is not operating at a sufficient precision level to ensure completeness and accuracy of the key elements. Additionally, effective controls were not in place to ensure timely reporting.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department continue to enhance policies and procedures which include internal controls across the Department programs to which FFATA reporting is applicable, to ensure timely and accurate reporting to the FSRS system to ensure compliance with the Transparency Act reporting requirements.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014
COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W)
Federal Award Numbers: S425D210017, S425U210017
Federal Award Year: 2021
U.S. Department of Education
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-008
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report.
Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include:
1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code
2. Line 3.b10 Number of specific positions supported with ESSER Funds
3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools
4. Line 5.a Full Time Equivalent positions
Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies).
During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following:
A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423.
B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436.
C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436.
D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760.
E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835.
F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512.
G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837.
Cause
The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed.
Questioned Costs: None.
Recommendation
We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-015
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 2 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 2 FFATA reports selected for testwork, the UEI number did not agree to the underlying supporting documentation as the UEI number was not included in the subaward agreement.
C. For 1 of 2 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 2 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$548,250 N/A $510,000 N/A $548,250
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-016
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2101NHCMC6-01, 2101NHCMC6-02, 2201NHOACM-02, 2201NHOACM-00, 2201NHOACM-03, 2201NHOACM-04, 2201NHOAHD-03, 2201NHOAHD-00, 2201NHOAHD-02, 2301NHOASS-02, 2301NHOACM-02, 2301NHOACM-01, 2301NHOAHD-01, 2301NHOAHD-02
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Costs Principles
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Funds may be used for nutrition services and supportive services consistent with the terms of the agreement between the Area Agency and the service provider (42 USC 3026(a)(1), 3030d(a), and 3030e).
Funds may be used for the provision of home-delivered meals to older individuals (42 USC 3030f).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
The New Hampshire Department of Health and Human Services (the Department) enters into subrecipient agreements with local area agencies that provide supportive services and nutrition programs. These programs include providing meals both in a congregate group setting as well as home delivery for older individuals.
During our testwork over the allowability of costs charged to the program, for 18 of 40 invoices selected for testwork, there was no evidence the Department had ensured the accuracy of the amount being billed prior to payment. While there was no evidence that these invoices had been reviewed and approved, the amount paid appeared to be properly supported by the invoice.
Cause
The cause of the condition found is due to insufficient policies and procedures to review the accuracy of the amount being billed. For certain invoices the Department uses the Options Electronic Billing and Service Authorization Maintenance System (the System). Once the subrecipient is authorized within the System to provide services and up to a certain amount of funding, the subrecipient electronically submits an invoice for the dates of services provided. The System performs validation that will verify that the subrecipient is approved to provide the service for the dates requested and if there is money remaining within the amount authorized, the request for reimbursement will be paid. The Department does not review the accuracy of the invoiced amount either prior to payment or subsequent to payment through its subrecipient monitoring procedures.
Effect
The effect of the condition found is that reimbursements could be made to subrecipient grants that are not properly supported by the subrecipients books and records resulting in unallowable costs.
Questioned Costs: None.
Recommendation
We recommend that the Department develop written policies and procedures and implement internal controls over the review and approval of invoices submitted through the Options Electronic Billing and Service Authorization Maintenance System. This would include procedures to review meal count information maintained by the subrecipient either prior to or subsequent to the reimbursement of costs to the subrecipient to ensure the accuracy of the amount being billed by the subrecipient.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17
NH Department of Health and Human Services
Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053)
Federal Award Number: 2401NHOASS, 2301NHOASS
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed.
B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed.
D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient.
E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-018
NH Department of Health and Human Services
Immunization Cooperative Agreements and COVID-19 Immunization Cooperative Agreements (Assistance Listing #93.268)
Federal Award Number: NH23IP922595
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of the 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported in the FFATA report as it was not included within the subaward agreement.
C. For all 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 3 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$430,000 N/A $430,000 N/A $30,000
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-018
NH Department of Health and Human Services
Immunization Cooperative Agreements and COVID-19 Immunization Cooperative Agreements (Assistance Listing #93.268)
Federal Award Number: NH23IP922595
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of the 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported in the FFATA report as it was not included within the subaward agreement.
C. For all 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 3 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$430,000 N/A $430,000 N/A $30,000
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-019
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Number: NUK50CK000522
Federal Award Year: 2021, 2022
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2022-010
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Quarterly fiscal reports are required to be submitted beginning 69 days after the notice of Awards is issued.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
Quarterly Reporting
As part of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, the New Hampshire Department of Health and Human Services (the Department) reports financial information to the Centers for Disease Control (CD) on a quarterly basis related to expenditures incurred and the amount of unliquidated obligations for the reporting period. During our testwork over quarterly reporting, we identified that for 12 of 27 quarterly reports selected for testwork, we were unable to obtain a copy of the report summary for the reporting period selected for testwork. As a result, were unable to verify that the that the unliquidated obligation for the reporting period was properly reported.
FFATA Reporting
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 4 FFATA reports selected for testwork, we were unable to validate the UEI number as it was not included within the subaward.
C. For 1 of 4 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 1 N/A 4
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,947,055 N/A $266,603 N/A $1,947,055
Cause
The cause of the condition found related to quarterly reporting is that the Department did not maintain a screenshot of the unliquidated obligations reported for COVID related federal awards. The federal reporting system does not allow the user to review prior submissions and only shows the status of the grant, including the unliquidated obligation balance. The only thing that appears in the federal reporting system is the current status of the grant.
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department does not have sufficient documentation to support the unliquidated obligation balances for COVID related quarterly reports the amounts reported may not have been accurately filed. In addition, the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures related to monthly reporting to ensure that a copy of all quarterly financial reports summary for all COVID grants maintained to properly document that the unliquidated obligation is properly reported.
We further recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA reports prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-019
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Number: NUK50CK000522
Federal Award Year: 2021, 2022
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2022-010
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Quarterly fiscal reports are required to be submitted beginning 69 days after the notice of Awards is issued.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
Quarterly Reporting
As part of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, the New Hampshire Department of Health and Human Services (the Department) reports financial information to the Centers for Disease Control (CD) on a quarterly basis related to expenditures incurred and the amount of unliquidated obligations for the reporting period. During our testwork over quarterly reporting, we identified that for 12 of 27 quarterly reports selected for testwork, we were unable to obtain a copy of the report summary for the reporting period selected for testwork. As a result, were unable to verify that the that the unliquidated obligation for the reporting period was properly reported.
FFATA Reporting
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For each of the 4 FFATA reports selected for testwork, we were unable to validate the UEI number as it was not included within the subaward.
C. For 1 of 4 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 1 N/A 4
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,947,055 N/A $266,603 N/A $1,947,055
Cause
The cause of the condition found related to quarterly reporting is that the Department did not maintain a screenshot of the unliquidated obligations reported for COVID related federal awards. The federal reporting system does not allow the user to review prior submissions and only shows the status of the grant, including the unliquidated obligation balance. The only thing that appears in the federal reporting system is the current status of the grant.
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department does not have sufficient documentation to support the unliquidated obligation balances for COVID related quarterly reports the amounts reported may not have been accurately filed. In addition, the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: Not determinable.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures related to monthly reporting to ensure that a copy of all quarterly financial reports summary for all COVID grants maintained to properly document that the unliquidated obligation is properly reported.
We further recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA reports prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-020
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Numbers: NUK50CK000522
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-011
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient.
B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-020
NH Department of Health and Human Services
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323)
Federal Award Numbers: NUK50CK000522
Federal Award Year: 2019
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-011
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient.
B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-021
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-015
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity must:
• Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a);
• Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521.
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2024, $38,545,693 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following:
A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 4 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated:
a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414)
b. Identification of whether the award is R&D
B. The data that is used to compile the Annual Report on Households Assisted by LIHEAP is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate.
Cause
The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that award information is appropriately communicated and that there is appropriate monitoring procedures performed over the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports.
Effect
The effect of the condition found is that the Department did not comply with section 2 CFR 200.332 (a) and 2 CFR 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that all required award identification information is communicated to subrecipients and over the monitoring of data submitted by subrecipients to be used in the Annual Report on Households Assisted by LIHEAP to ensure that the report is complete and accurate.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-022
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-016
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Annual Report on Households Assisted by LIHEAP (OMB No. 0970-0060) – As part of the application for block grant funds each year, a report is required for the preceding fiscal year of (1) the number and income levels of the households assisted for each component and any type of LHEAP assistance (heating, cooling, crisis, and weatherization); and (2) the number of households served that contained young children, elderly, or persons with disabilities, or any vulnerable household for each component. Territories with annual allotments of less than $200,000 and all Native American tribes are required to report only on the number of households served for each program component (42 USC 8629; 45 CFR section 96.82).
Quarterly Performance and Management Report (OMB No. 0970-0589) https://omb.report/icr/202205-0970-017/doc/121847100 – Grant recipients must submit data and information about LIHEAP during the current FY, including success, challenges, needs and innovations. The quarterly reports focus on assisted households, performance management, obligation of funding, changes made due to anticipated increase in energy bills, collaboration with other utility programs, and training and technical assistance needs.
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over federal reporting as part of the Low-Income Home Energy Assistance program (LIHEAP), we noted the following:
A. During our testwork over FFATA report completed by the New Hampshire Department of Energy (the Department), we identified that for 1 of 3 FFATA reports selected for testwork that the FFATA report was not submitted timely.
Reports Tested Subaward not reported Report not timely Subaward amount incorrect Subaward incorrect key elements
4 0 1 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$86,991,138 $0 $26,928,592 $0 $0
B. The Annual Report on Households Assisted by LIHEAP report was submitted by the Department’s externally engaged consultants, APPRISE, for both program year ending September 30, 2023 and September 30, 2024. For this process, the Department submitted raw data files retrieved from their subrecipients to APPRISE to utilize in the development of the balances submitted within the report. The Department was unable to provide us with supporting documentation that reconciled to the balances submitted within the report, as the balances submitted were developed by APPRISE. As they were unable to provide us with supporting documentation behind the balances submitted, we were unable to determine the report submitted was complete and accurate. We further identified that for the report submitted for program year September 30, 2024, the report was required be resubmitted due to an error being discovered by APPRISE after their submission of the report.
C. During our testwork related to the Quarterly Performance and Management Reports, we identified the following:
a. For 1 of 4 quarterly reports tested, we were unable to determine whether the report was submitted as the report provided was not signed and dated by the Program Director.
b. For the Quarterly Performance and Management report submitted for the quarters ended September 30, 2023 and December 31, 2023, we were unable to verify to obtain documentation to support the following key line items:
i. Number of assisted households during the same period last year for the same quarter x for federal fiscal year 2023,
ii. Total amount of funds obligated for LIHEAP fiscal year 2023 allotment
iii. Amount of funds obligated for other supplemental allotment.
Cause
The cause of the condition found related primarily to insufficient resources to ensure reports are filed and complete and accurate. In addition, the Department did not have procedures in place to ensure it reconciled reports prepared by their contractor to ensure that the reports were accurately filed.
Effect
The effect of the condition found is that the required reports may not be submitted and accurate and their are sufficient internal controls to identify errors or non-submission.
Questioned Costs: None.
Recommendation
We recommend that the Department should review to ensure there is sufficient safeguards in place for professionals to perform when positions are vacant so that necessary processes are completed related to compliance with federal requirements, including submission of federal reports, including FFATA reports. In addition, we recommend that the Department implement written policies and procedures for the compilation and review of the Quarterly Performance and Management Report and Annual Report on Households Assisted by LIHEAP and ensure that the documentation to support the amounts reported is maintained to support that the report is complete and accurate.
View of Responsible Official: Management concurs with the finding above.
Finding Reference Number: 2024-023
NH Department of Energy
Low Income Home Energy Assistance (Assistance Listing #93.568)
Federal Award Numbers: 2301NHLIEA, 2401NHLIEA
Federal Award Year: 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Cash Management
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-014
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over federal reporting as part of the Low-Income Home Energy Assistance program (LIHEAP), we noted the New Hampshire Department of Energy (the Department) advances payments to subrecipients to ensure that they have sufficient cash on hand in order to pay for benefit payments. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $38,545,693 to subrecipients during the year ended June 30, 2024. During our testwork over cash management, we noted that for the 4 cash advance payment samples selected for testwork, while the Department properly tracks subrecipient's expenditures, the Department does not ensure that the amount of time the cash on hand is minimized. The engagement team noted that for all 4 samples tested, cash is on hand for over 30 days according to each tracking sheet maintained by management.
Cause
The cause of the condition found was primarily due to insufficient monitoring procedures and internal controls to ensure that subrecipients either utilized advanced funds timely or effectively evaluate the amount of funds the subrecipient would need to have on hand at the time of the advance payment.
Effect
The effect of the condition found is that the Department was not in compliance with 2 CFR section 200.204(b)(1).
Questioned Costs: None.
Recommendation
We recommend that the Department continue to review its existing internal controls, policies, and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-024
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For all 3 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 2 of 3 FFATA reports selected for testwork, we were unable to verify the UEI number reported as the UEI number was not included on the subaward agreement.
C. For 1 of the 3 FFATA reports selected for testwork, the report was not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
3 N/A 1 N/A 2
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$5,793,670 N/A $750,000 N/A 4,293,670
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025
NH Department of Health and Human Services
CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596)
Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD
Federal Award Year: 2021, 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-026
NH Department of Health and Human Services
Opioid STR (Assistance Listing #93.788)
Federal Award Number: H79TI081685, H79TI083326, H79TI085759
Federal Award Year: 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements –Clearly identify to the subrecipient the award as a subrecipient by providing the information prescribed in 2 CFR 200.332(a)
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $21,190,358 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following:
A. For 3 of 7 subrecipients selected for testwork, per review of the award communication, the Department did not properly communicate the indirect cost rate for the federal award.
B. For 1 of 7 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. We noted that while there no monitoring procedures listed, the Department did complete a monthly expenditure detail review.
C. For 1 of 7 subrecipients selected for testwork, the risk assessment indicated that an annual onsite monitoring review was to be conducted. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period.
Cause
The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that the required award identification information is communicated to all subrecipients and to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management partially concurs with the finding above.
Rejoinder: As documented in Bullet B above, the risk assessment provided by the Department for 1 of 7 subrecipients did not contain any suggested monitoring procedures. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
Finding Reference Number: 2024-027
NH Department of Health and Human Services
Opioid STR (Assistance Listing #93.778)
Federal Award Number: H79TI081685, H79TI083326, H79TI085759
Federal Award Year: 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following that for all 7 FFATA reports selected for testwork, there was no evidence that the reports were reviewed and approved prior to submission. While there was no evidence of review, the reports appeared to be complete, accurate and filed timely.
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-028
NH Department of Health and Human Services
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01
Federal Award Year: 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-017
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-028
NH Department of Health and Human Services
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01
Federal Award Year: 2022, 2023
U.S. Department of Health and Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-017
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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
Condition
During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place.
Cause
The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department.
Effect
The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f).
Questioned Costs: None.
Recommendation
We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-029
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08T083509, 1B08T1084595, 1B08T1083464, 6B08T103464, 1B08T1084659, B08T108521
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 3 of 4 FFATA reports selected for testwork, we were unable to validate the UEI number was not included within the subaward agreement.
C. For 3 of 4 FFATA reports, the reports were not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 3 2 3
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,545,840 N/A $6,788,363 $5,442,523 $1,345,840
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-029
Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959)
Federal Award Numbers: 1B08T083509, 1B08T1084595, 1B08T1083464, 6B08T103464, 1B08T1084659, B08T108521
Federal Award Year: 2021, 2022, 2023, 2024
U.S. Department of Health and Human Services
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 45 CFR section 75 303(a) states the non-Federal entity must 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.
Condition
During our testwork over FFATA reporting, we identified the following:
A. For each of the 4 FFATA reports selected for testwork, there was no evidence provided that the report was reviewed and approved prior to submission.
B. For 3 of 4 FFATA reports selected for testwork, we were unable to validate the UEI number was not included within the subaward agreement.
C. For 3 of 4 FFATA reports, the reports were not filed timely.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
4 N/A 3 2 3
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,545,840 N/A $6,788,363 $5,442,523 $1,345,840
Cause
The cause of the condition found related to FFATA reporting is due to insufficient controls related to the review and approval of FFATA reports to ensure the accuracy of the data reported. During the period ending June 30, 2024, due to staffing changes, the same individual was preparing and submitting the FFATA report, resulting in a lack of segregation of duties over the review and approval of the FFATA report.
Effect
The effect of the condition found is that the Department did not comply with the Transparency Act reporting requirements.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. This would include ensuring that a supervisory review is performed over the FFATA report prior to submission.
View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-030
NH Department of Education
Disability Insurance/SSI Cluster (Assistance Listing #96.001)
Federal Award Numbers: 2304NHDI00, 2404NHD100
Federal Award Year: 2023, 2024
U.S. Social Security Administration
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-019
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
The SSA-4513 – State Agency Report of Obligations for SSA Disability Programs – is due quarterly for each fiscal year still open in order to account for program disbursements and unliquidated obligations (POMS DI 39506.202).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over federal reporting related to the SSA-4513 quarterly report, we identified the following:
A. For all 4 of 9 SSA-4513 reports selected for testwork, line item 7 was not checked to identify if the SSA-871 needed to be attached to the report. It is unclear if this needed to be attached or not.
B. For all 9 SSA-4513 reports selected for testwork, the reports did not reconcile to the internal tracking sheets provided to validate the amounts reported. For all reports there were variances between the tracking sheets and the dollar amounts included within the federal report within sections 1, 2, 3 and 4. While variances are identified, we noted that the variances were not material overall to the individual line item.
C. For all 9 SSA-4513 reports selected for testwork, we were unable to validate the completeness and accuracy of the amounts reported within Section 1 for Columns (A) for Disbursements, (B) for unliquidated obligations and (C) total obligations for line items 1, 2, 3 and 4. As such, we are not able to validate that the amounts reported are complete and accurate. As we were not able to obtain documentation to validate the obligation balances, we are unable to validate the accuracy of amounts reported within Sections 1, 2, and 3 of the report.
D. For all 9 of the SSA-4513 reports selected for testwork, there was no support for the difference between the total obligations and cumulative obligational authorization.
E. For 1 of 9 SSA-4513 reports selected for testwork, no supporting documentation was provided.
F. For 8 of 9 SSA-4513 reports selected for testwork, documentation was not provided for Line Item 2.d, Other Identity obligation & amount
Cause
The cause of the condition found related to the SSA-4513 was due to insufficient policies and procedures to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed. Based on the documentation that was provided to support the data reported within each quarterly report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate.
Effect
The effect of the condition found is the SSA-4134 reports were not complete and accurate when they were filed.
Questioned Costs: None.
Recommendation
We recommend that the existing policies and procedures be developed to ensure that all documentation to support the amounts reported on the SSA-4513 is properly maintained for each quarterly report. In addition, internal control procedures should be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documenting showing that the required review process was performed prior to submitting the SSA-4513.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-031
NH Department of Education
Disability Insurance/SSI Cluster (Assistance Listing #96.001)
Federal Award Numbers: 2304NHDI00, 2404NHD100
Federal Award Year: 2023, 2024
U.S. Social Security Administration
Compliance Requirement: Special Tests and Provisions – Qualified Providers
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-020
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Each state agency is responsible for comprehensive oversight management of its process and for ensuring accuracy, integrity, and economy of its processes (20 CFR sections 404.519g and 416.919g, and POMS DI 396569.300). As part of these duties, DDSs must have and follow procedures for performing medical license verifications to ensure that only qualified providers perform DDSs tasks. By “qualified,” SSA means that the medical source must:
1. Be currently licensed in the state and have the training and experience to perform the type of examination or tests DDS requests; and
2. Not be barred from participating in Medicare or Medicaid programs or other federal or federally assisted programs (20 CFR sections 404.5159g and 416.919g). Prior to using the services of any medical provider, the DDS must check the System of Award Management (SAM) website.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
During our testwork over the special test and provision related to qualified providers, we identified the following 9 of 9 exceptions:
A. For 2 of the 9 new providers selected for testwork, there was no documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for new providers and no information was provided to support the provider had a valid medical license.
B. For 3 of the 9 new providers selected for testwork, there was no documentation maintained to support the start date of the individual to verify the inspection of the SAM.gov website was performed prior to use of the provider’s service.
C. For the remaining 4 of the 9 new providers selected for testwork, the supporting documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for the provider occurred subsequent to the individual’s start date.
Cause
The cause of the condition found is primarily due to insufficient policies and procedures to verify a provider’s had a valid medical license or the provider’s suspension and debarment status had been reviewed within SAM.gov prior to use of services by the provider as required by the federal regulations. In response to the prior year finding corrective actions were being implemented after June 30, 2024 and not all personnel were following the policies and procedures. There does not appear to be sufficient internal controls in place to ensure that reviews of provider’s licenses and suspension and debarment status are performed, completed and properly documented and sufficient documentation is maintained and reviewed.
Effect
The effect of the condition found is that documentation to support the qualifications of providers has not been appropriately maintained and providers could have been used that did not meet the criteria to be a qualified provider.
Questioned Costs: Not determinable.
Recommendation
We recommend that written policies and procedures be developed and followed by all personnel to outline what the required procedures are related to reviewing professional licenses and suspension and debarment status for new provider. The policies should describe how the reviews will be performed, how the review will be documented, and the timing of when reviews will be performed relative to the provider’s start date. Internal controls should be implemented to ensure that an appropriate review over the review is conducted to ensure that the review is performed, completed and accurate documentation maintained.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR
Federal Award Year: July 29-30, 2021, July 1-2, 2017
U.S. Department of Homeland Security
Compliance Requirement: Special Tests and Provisions - Project Accounting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-021
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following:
A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to.
B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided.
Cause
This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation.
Effect
The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a).
Questioned Costs: None.
Recommendation
We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR
Federal Award Year: July 29-30, 2021, July 1-2, 2017
U.S. Department of Homeland Security
Compliance Requirement: Special Tests and Provisions - Project Accounting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-021
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following:
A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to.
B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided.
Cause
This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation.
Effect
The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a).
Questioned Costs: None.
Recommendation
We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024
U.S. Department of Homeland Security
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following:
A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely.
B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported.
C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
8 1 10 Unknown Unknown
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,616,072 $919,070 Unknown Unknown Unknown
Cause
The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate.
Effect
The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024
U.S. Department of Homeland Security
Compliance Requirement: Reporting
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: N/A
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following:
A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely.
B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported.
C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing.
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
8 1 10 Unknown Unknown
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$1,616,072 $919,070 Unknown Unknown Unknown
Cause
The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate.
Effect
The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed.
Questioned Costs: None.
Recommendation
We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely.
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020
U.S. Department of Homeland Security
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-023
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following:
A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated:
• Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and
• Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork
B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures.
C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely.
D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted:
• For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year.
• For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report.
Cause
The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures.
Questioned Costs: None.
Recommendation
We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h).
View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034
NH Department of Safety
Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036)
Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH
Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020
U.S. Department of Homeland Security
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness and Material Noncompliance
Prior Year Finding: 2023-023
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Criteria
A pass-through entity (PTE) must:
1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)).
2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following:
a. Reviewing financial and programmatic (performance and special reports) required by the PTE.
b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.
c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide 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.
Condition
As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters.
During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following:
A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated:
• Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and
• Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork
B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures.
C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely.
D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted:
• For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year.
• For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report.
Cause
The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures.
Questioned Costs: None.
Recommendation
We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h).
View of Responsible Officials: Management concurs with the finding above.