FAC Explorer

Audit 356420

FY End
2024-06-30
Total Expended
$4.10M
Findings
4
Programs
10
Organization: Aclamo (PA)
Year: 2024 Accepted: 2025-05-15
Auditor: Wentzel and Company PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
560521 2024-002 Significant Deficiency - I
560522 2024-003 Significant Deficiency - L
1136963 2024-002 Significant Deficiency - I
1136964 2024-003 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.32M Yes 2
21.023 Emergency Rental Assistance Program $867,629 Yes 0
93.558 Temporary Assistance for Needy Families $260,008 - 0
17.225 Unemployment Insurance $179,879 - 0
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $112,500 - 0
97.088 Disaster Assistance Projects $71,224 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $67,416 - 0
93.268 Immunization Cooperative Agreements $21,442 - 0
93.568 Low-Income Home Energy Assistance $6,612 - 0
81.042 Weatherization Assistance for Low-Income Persons $4,732 - 0

Contacts

Name Title Type
LHRJBJK32WH6 Beatriz Gasiba Auditee
6102772570 Vivian Wentzel Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 – BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. ACLAMO has elected to not use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of ACLAMO under programs of the federal government for the year ended June 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of ACLAMO, it is not intended to and does not present the financial position, changes in net assets, or cash flows of ACLAMO.
Title: NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. ACLAMO has elected to not use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. ACLAMO has elected to not use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: NOTE 3 – AMOUNTS PASSED TO SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. ACLAMO has elected to not use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. ACLAMO did not provide federal awards to subrecipients for the year ended June 30, 2024.
Title: NOTE 4 – RELATIONSHIP TO BASIC FINANCIAL STATEMENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. ACLAMO has elected to not use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal awards expenditures are reported on the statement of functional expenses as program services. In certain programs, the expenditures reported in the basic financial statements may differ from the expenditures reported in the schedule of federal expenditures due to program expenditures exceeding grant or contract budget limitations not included as federal awards. Program expenditures on the schedule of expenditures of federal awards may also differ from government revenues in the financial statements because of changes in restricted net assets resulting from unexpended revenues.

Finding Details

Finding 2024-002
2024-002: Procurement Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization’s procurement policies were not followed when selecting the major contractors for the expansion project. Specifically, there was no documentation maintained for federal compliance checks or the evaluation and ranking of candidates by the infrastructure committee. Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws; this includes maintaining records that detail the history of procurement. Cause: The organization does not have effective controls in place to ensure the procurement policies and procedures are followed. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Coronavirus State and Local Fiscal Recovery Funds program. It also increases the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 contractors was selected for testing of Procurement. Repeat Finding from Prior Year: No. Recommendation: The organization should provide training for staff involved in procurement to ensure they understand and follow the documented policies, conduct periodic reviews of procurement activities to verify compliance with the policies, and maintain documentation of the procurement activities. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. We have taken steps to strengthen compliance and oversight. We are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve a designated Construction Manager to monitor compliance with standardized procedures and reporting throughout the project, that meeting minutes are properly recorded by the grantor’s requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. ACLAMO will provide mandatory training for all staff involved in the procurement process and will conduct a comprehensive review of its procurement policy to ensure alignment with Uniform Guidance.
Finding 2024-003
2024-003: Reporting Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization did not retain copies of the quarterly reports filed with the county or confirmation of the submission. Criteria: Under the subrecipient agreement, the organization was required to submit quarterly reports to Montgomery County by the 15th of the following month. Internal controls should be in place over retention of supporting documentation to verify reports were filed accurately and timely. Cause: Internal controls over document retention for filed reports are inadequately designed and copies of reports or proof of submission were not maintained. Effect: Because copies of reports or proof of submission were not maintained, there is no supporting documentation to show that the reports were filed accurately or timely. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 quarterly reports was selected for testing of Reporting. Repeat Finding from Prior Year: No. Recommendation: The organization should develop procedures to ensure that copies of filed reports or proof of submission are maintained. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. Following report submission, we will request confirmation of receipt and a copy of the submitted report, which will be stored on the Financial Team SharePoint site. ACLAMO will also implement a formal tracking system to document submission dates, confirmation receipts, and responsible staff members. Relevant team members will receive training on proper document retention procedures.
Finding 2024-002
2024-002: Procurement Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization’s procurement policies were not followed when selecting the major contractors for the expansion project. Specifically, there was no documentation maintained for federal compliance checks or the evaluation and ranking of candidates by the infrastructure committee. Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws; this includes maintaining records that detail the history of procurement. Cause: The organization does not have effective controls in place to ensure the procurement policies and procedures are followed. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Coronavirus State and Local Fiscal Recovery Funds program. It also increases the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 contractors was selected for testing of Procurement. Repeat Finding from Prior Year: No. Recommendation: The organization should provide training for staff involved in procurement to ensure they understand and follow the documented policies, conduct periodic reviews of procurement activities to verify compliance with the policies, and maintain documentation of the procurement activities. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. We have taken steps to strengthen compliance and oversight. We are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve a designated Construction Manager to monitor compliance with standardized procedures and reporting throughout the project, that meeting minutes are properly recorded by the grantor’s requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. ACLAMO will provide mandatory training for all staff involved in the procurement process and will conduct a comprehensive review of its procurement policy to ensure alignment with Uniform Guidance.
Finding 2024-003
2024-003: Reporting Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization did not retain copies of the quarterly reports filed with the county or confirmation of the submission. Criteria: Under the subrecipient agreement, the organization was required to submit quarterly reports to Montgomery County by the 15th of the following month. Internal controls should be in place over retention of supporting documentation to verify reports were filed accurately and timely. Cause: Internal controls over document retention for filed reports are inadequately designed and copies of reports or proof of submission were not maintained. Effect: Because copies of reports or proof of submission were not maintained, there is no supporting documentation to show that the reports were filed accurately or timely. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 quarterly reports was selected for testing of Reporting. Repeat Finding from Prior Year: No. Recommendation: The organization should develop procedures to ensure that copies of filed reports or proof of submission are maintained. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. Following report submission, we will request confirmation of receipt and a copy of the submitted report, which will be stored on the Financial Team SharePoint site. ACLAMO will also implement a formal tracking system to document submission dates, confirmation receipts, and responsible staff members. Relevant team members will receive training on proper document retention procedures.