Audit 352209

2024 – 002 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization did not have a written procurement policy in accordance with Uniform Guidance for a portion of the year. In addition, during our testing, we noted the Organization did not apply the proper procurement procedures for two vendors as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance. Questioned Costs: Unknown Context: Two out of the two procurement selections did not have procurement procedures followed. Cause: Vendors were procured prior to the implementation of a formal procurement policy; therefore, proper documentation was not retained as of the procurement date. Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards. Repeat Finding: This is a repeat finding. Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Views of Responsible Officials and Planned Corrective Actions: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements.

2024 – 003 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing we noted the Organization does not have formal suspension and debarment procedures. Questioned Costs: N/A Context: One of the one selections did not have any suspension/debarment procedures followed until after entering into the covered transaction as the policy in place only requires the search be performed. Cause: Management was aware of the suspension and debarment requirements dictated by the Uniform Guidance; however, the client's policy is not formally documented and does not include a required time frame. Effect: Potential for the Organization to do business with entities that are suspended or debarred which is not allowed per Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement a formal internal control policy over the suspension and debarment rules and follow them before entering into a covered transaction with another entity. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement and follow a suspension and debarment policy in accordance with 2 CFR section 180.995 and specify the review of a vendor must be done prior to entering into a covered transaction.

2024 – 004 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award and Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Under 2 CFR section 200.303, a nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Timely review and approval should be maintained to ensure accurate amounts are being drawn down and accurate reports are submitted. Condition: The Organization did not have adequate internal controls in place for the full fiscal year to ensure cash drawdowns and required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: Two of the three reimbursement requests and five of the five reports selected for testing did not have support retained to show the drawdowns, financial status reports, and other performance reports were reviewed and approved prior to submission. Cause: Management did not have a separate individual assigned to review the cash drawdowns and required reports for the Crime Victim Assistance program after being prepared by the Director of Finance for the full fiscal year. Effect: Potential for inaccurate amounts of funds to be requested or inaccurate information reported. Repeat Finding: This is a repeat finding. Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Views of Responsible Officials and Planned Corrective Actions: The Organization has designated an individual to review and approve the cash drawdowns and reports prior to submission.

2024 – 002 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization did not have a written procurement policy in accordance with Uniform Guidance for a portion of the year. In addition, during our testing, we noted the Organization did not apply the proper procurement procedures for two vendors as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance. Questioned Costs: Unknown Context: Two out of the two procurement selections did not have procurement procedures followed. Cause: Vendors were procured prior to the implementation of a formal procurement policy; therefore, proper documentation was not retained as of the procurement date. Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards. Repeat Finding: This is a repeat finding. Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Views of Responsible Officials and Planned Corrective Actions: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements.

2024 – 003 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing we noted the Organization does not have formal suspension and debarment procedures. Questioned Costs: N/A Context: One of the one selections did not have any suspension/debarment procedures followed until after entering into the covered transaction as the policy in place only requires the search be performed. Cause: Management was aware of the suspension and debarment requirements dictated by the Uniform Guidance; however, the client's policy is not formally documented and does not include a required time frame. Effect: Potential for the Organization to do business with entities that are suspended or debarred which is not allowed per Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement a formal internal control policy over the suspension and debarment rules and follow them before entering into a covered transaction with another entity. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement and follow a suspension and debarment policy in accordance with 2 CFR section 180.995 and specify the review of a vendor must be done prior to entering into a covered transaction.

2024 – 004 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award and Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Under 2 CFR section 200.303, a nonfederal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Timely review and approval should be maintained to ensure accurate amounts are being drawn down and accurate reports are submitted. Condition: The Organization did not have adequate internal controls in place for the full fiscal year to ensure cash drawdowns and required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: Two of the three reimbursement requests and five of the five reports selected for testing did not have support retained to show the drawdowns, financial status reports, and other performance reports were reviewed and approved prior to submission. Cause: Management did not have a separate individual assigned to review the cash drawdowns and required reports for the Crime Victim Assistance program after being prepared by the Director of Finance for the full fiscal year. Effect: Potential for inaccurate amounts of funds to be requested or inaccurate information reported. Repeat Finding: This is a repeat finding. Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Views of Responsible Officials and Planned Corrective Actions: The Organization has designated an individual to review and approve the cash drawdowns and reports prior to submission.