Audit 357546

Criteria: 2 CFR Section 200.318 requires that the non-federal entity must have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity’s documented procurement procedures must conform to the procurement standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition and context: During testing of the Alliance’s controls on compliance over procurement and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check. Effect: The Alliance was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over procurement and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Criteria: 2 CFR Section 200.328 requires that the non-federal entity must submit the Federal Financial Report (SF-425) no later than 30 days after the end of a quarterly or semiannually reporting period (or 90 days for annual reporting periods). Condition and context: During testing of the Alliance’s compliance over reporting, we identified the Alliance did not submit the SF-425 forms timely during the year ended September 30, 2024. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not fully in compliance with the reporting requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance implement internal controls such as a compliance calendar and designated review procedures to ensure that all federal reporting requirements, including SF-425 filings, are completed accurately and on time. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Criteria: Per 2 CFR Section 170, the prime recipients of federal grants that make subawards of $30,000 or more are required to report specific information about those subawards in the Federal Subaward Reporting System (FSRS), that is, the Federal Funding Accountability and Transparency Act (FFATA) report, by the end of the month following the month in which the subaward was obligated. Condition and context: During testing of the Alliance’s compliance with FFATA reporting requirements, we identified the Alliance did not submit FFATA reports timely. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not in compliance with the reporting requirements of the Uniform Guidance. Failure to report subawards in a timely manner may affect the government’s ability to provide adequate oversight and may be considered noncompliance with award terms and conditions. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance establish formal policies and procedures to ensure compliance with FFATA reporting requirements, including identifying applicable subawards and submitting reports through FSRS in a timely manner. Views of Responsible Official:Management agrees with the finding. See Corrective Action Plan.

Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses. Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards. Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Criteria: 2 CFR Section 200.318 requires that the non-federal entity must have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity’s documented procurement procedures must conform to the procurement standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition and context: During testing of the Alliance’s controls on compliance over procurement and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check. Effect: The Alliance was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over procurement and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Criteria: 2 CFR Section 200.328 requires that the non-federal entity must submit the Federal Financial Report (SF-425) no later than 30 days after the end of a quarterly or semiannually reporting period (or 90 days for annual reporting periods). Condition and context: During testing of the Alliance’s compliance over reporting, we identified the Alliance did not submit the SF-425 forms timely during the year ended September 30, 2024. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not fully in compliance with the reporting requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance implement internal controls such as a compliance calendar and designated review procedures to ensure that all federal reporting requirements, including SF-425 filings, are completed accurately and on time. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Criteria: Per 2 CFR Section 170, the prime recipients of federal grants that make subawards of $30,000 or more are required to report specific information about those subawards in the Federal Subaward Reporting System (FSRS), that is, the Federal Funding Accountability and Transparency Act (FFATA) report, by the end of the month following the month in which the subaward was obligated. Condition and context: During testing of the Alliance’s compliance with FFATA reporting requirements, we identified the Alliance did not submit FFATA reports timely. Cause: The Alliance’s controls and processes were not effectively designed to ensure all reporting requirements are executed timely. Effect: The Alliance was not in compliance with the reporting requirements of the Uniform Guidance. Failure to report subawards in a timely manner may affect the government’s ability to provide adequate oversight and may be considered noncompliance with award terms and conditions. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance establish formal policies and procedures to ensure compliance with FFATA reporting requirements, including identifying applicable subawards and submitting reports through FSRS in a timely manner. Views of Responsible Official:Management agrees with the finding. See Corrective Action Plan.

Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses. Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards. Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.