2024-003 Subrecipient Monitoring and Allowable Costs – Material Weakness
Federal Programs – AL 64.033 – VA Supportive Services for Veteran Families
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures
in effect for CAPND employees to adequately monitor the subrecipients under the Supportive
Services for Veteran Families (SSVF) grant. Although the policies and procedures in effect
during the year ended December 31, 2024 were appropriately designed, they were not
completed throughout the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is not a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the SSVF program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the
year over SSVF policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-004 Allowable Costs
Federal Programs – AL 64.033 – Supportive Services for Veteran Families (SSVF)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)).
Condition – For the year ended December 31, 2024, we noted one instance in which noneligible
expense by a subrecipient were reimbursed and CAPND drew down on the grant for.
Cause – There was a request for by a subrecipient to reimburse expenses that did not exist.
This request was authorized by CAPND and the payment was sent to the subrecipient for noneligible
expenses. CAPND then drew down on the grant for the non-existing expense.
Effect – Noncompliance with the grant.
Questioned costs – $159.73
Repeat Finding – This is not a repeat finding.
Recommendation – Implement a system of internal control in which all expenses that
subrecipient request to be reimbursed have supporting documentation.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-005 Subrecipient Monitoring
Federal Programs – AL 64.033 – Supportive Services for Veteran Families (SSVF)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)).
Condition – For the year ended December 31, 2024, we noted one instance in which noneligible
expense by a subrecipient were reimbursed and CAPND drew down on the grant for.
Cause – There was a request for by a subrecipient to reimburse expenses that did not exist.
This request was authorized by CAPND and the payment was sent to the subrecipient for noneligible
expenses. CAPND then drew down on the grant for the non-existing expense. Effect – Noncompliance with the grant.
Questioned costs – $159.73
Repeat Finding – This is not a repeat finding.
Recommendation – Implement a system of internal control in which all expenses that
subrecipient request to be reimbursed have supporting documentation.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-002 Subrecipient Monitoring – Material Weakness
Federal Programs – AL 93.569 – Community Service Block Grant
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community
Services Block Grant (CSBG). Although the policies and procedures in effect during the year
ended December 31, 2024 were appropriately designed, they were not completed throughout
the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the CSBG program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended
absences. In addition, training for all staff upon employment and periodically throughout the
year over CSBG policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-006 Subrecipient Monitoring
Federal Programs – AL 93.569 – Community Services Block Grant (CSBG)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2024, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – There was missing required information on subawards granted to subrecipients.
Context– Of the total federal expenditures under the program noted above, $283,852 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities for the grant year October 2023 to September 2024, all
five were missing the following required information under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is a repeat finding.
Recommendation – The entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-002 Subrecipient Monitoring – Material Weakness
Federal Programs – AL 93.569 – Community Service Block Grant
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community
Services Block Grant (CSBG). Although the policies and procedures in effect during the year
ended December 31, 2024 were appropriately designed, they were not completed throughout
the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the CSBG program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended
absences. In addition, training for all staff upon employment and periodically throughout the
year over CSBG policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-006 Subrecipient Monitoring
Federal Programs – AL 93.569 – Community Services Block Grant (CSBG)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2024, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – There was missing required information on subawards granted to subrecipients.
Context– Of the total federal expenditures under the program noted above, $283,852 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities for the grant year October 2023 to September 2024, all
five were missing the following required information under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is a repeat finding.
Recommendation – The entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-003 Subrecipient Monitoring and Allowable Costs – Material Weakness
Federal Programs – AL 64.033 – VA Supportive Services for Veteran Families
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures
in effect for CAPND employees to adequately monitor the subrecipients under the Supportive
Services for Veteran Families (SSVF) grant. Although the policies and procedures in effect
during the year ended December 31, 2024 were appropriately designed, they were not
completed throughout the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is not a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the SSVF program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended absences. In addition, training for all staff upon employment and periodically throughout the
year over SSVF policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-004 Allowable Costs
Federal Programs – AL 64.033 – Supportive Services for Veteran Families (SSVF)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)).
Condition – For the year ended December 31, 2024, we noted one instance in which noneligible
expense by a subrecipient were reimbursed and CAPND drew down on the grant for.
Cause – There was a request for by a subrecipient to reimburse expenses that did not exist.
This request was authorized by CAPND and the payment was sent to the subrecipient for noneligible
expenses. CAPND then drew down on the grant for the non-existing expense.
Effect – Noncompliance with the grant.
Questioned costs – $159.73
Repeat Finding – This is not a repeat finding.
Recommendation – Implement a system of internal control in which all expenses that
subrecipient request to be reimbursed have supporting documentation.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-005 Subrecipient Monitoring
Federal Programs – AL 64.033 – Supportive Services for Veteran Families (SSVF)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)).
Condition – For the year ended December 31, 2024, we noted one instance in which noneligible
expense by a subrecipient were reimbursed and CAPND drew down on the grant for.
Cause – There was a request for by a subrecipient to reimburse expenses that did not exist.
This request was authorized by CAPND and the payment was sent to the subrecipient for noneligible
expenses. CAPND then drew down on the grant for the non-existing expense. Effect – Noncompliance with the grant.
Questioned costs – $159.73
Repeat Finding – This is not a repeat finding.
Recommendation – Implement a system of internal control in which all expenses that
subrecipient request to be reimbursed have supporting documentation.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-002 Subrecipient Monitoring – Material Weakness
Federal Programs – AL 93.569 – Community Service Block Grant
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community
Services Block Grant (CSBG). Although the policies and procedures in effect during the year
ended December 31, 2024 were appropriately designed, they were not completed throughout
the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the CSBG program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended
absences. In addition, training for all staff upon employment and periodically throughout the
year over CSBG policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-006 Subrecipient Monitoring
Federal Programs – AL 93.569 – Community Services Block Grant (CSBG)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2024, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – There was missing required information on subawards granted to subrecipients.
Context– Of the total federal expenditures under the program noted above, $283,852 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities for the grant year October 2023 to September 2024, all
five were missing the following required information under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is a repeat finding.
Recommendation – The entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.
2024-002 Subrecipient Monitoring – Material Weakness
Federal Programs – AL 93.569 – Community Service Block Grant
Criteria – A good system of internal controls allows for the compliance with Uniform Guidance to
monitor funds that are passed through to subrecipients and the continued stewardship of those
federal dollars.
Condition – For the year ended December 31, 2024, we discussed the policies and procedures in effect for CAPND employees to adequately monitor the subrecipients under the Community
Services Block Grant (CSBG). Although the policies and procedures in effect during the year
ended December 31, 2024 were appropriately designed, they were not completed throughout
the year.
Cause – There was a general misunderstanding between staff and management on the process
of completing subrecipient monitoring controls throughout the year.
Effect – Noncompliance will not be prevented or detected and corrected in a timely manner.
Repeat Finding – This is a repeat finding.
Recommendation - The subrecipient monitoring policies and procedures should be updated to
include specific milestones and broken down into specific tasks that are to be achieved
throughout the year. These could then be monitored through meetings between the board
treasurer and the CSBG program coordinator. Redundancies and cross-training could be
included to reduce the risk that lapses in monitoring occur due to staff turnover or extended
absences. In addition, training for all staff upon employment and periodically throughout the
year over CSBG policies and procedures would allow for better clarity and understanding.
Views of Responsible Officials - Management recognizes the deficiency and plans to implement
the auditor’s recommendation.
2024-006 Subrecipient Monitoring
Federal Programs – AL 93.569 – Community Services Block Grant (CSBG)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2024, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – There was missing required information on subawards granted to subrecipients.
Context– Of the total federal expenditures under the program noted above, $283,852 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities for the grant year October 2023 to September 2024, all
five were missing the following required information under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is a repeat finding.
Recommendation – The entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.