Assistance Listing, Federal Agency, and Program Name 93.870, Maternal, Infant, and Early Childhood Home Visiting Grant
Federal Award Identification Number and Year S MIEC F 2022 9 2, 2024
Pass through Entity Children's Trust of South Carolina
Finding Type Material weakness
Repeat Finding No
Criteria Per the award agreement, awardees are required to submit Financial Request for Payments (FRP) at least quarterly by the end of the month following the month to be invoiced.
Condition The Organization had a control to review and certify the Financial Request for Payment; however, the control was ineffective and resulted in untimely submission of the request to the awarding agency.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context Out of a sample of eight Financial Requests for Payment, we identified one that was not certified or submitted within the required timeframe. The FRP was certified one day after the submission deadline and submitted five days after the submission deadline.
Cause and Effect The Organization designed controls related to reviewing and certifying the FRPs; however, the review process did not ensure that requests were submitted on time. The failure to have an effective control in place caused the Organization to not meet the submission date.
Recommendation We recommend that the review process include procedures to ensure prompt submission to meet the reporting requirements associated with the award.
Views of Responsible Officials and Corrective Action Plan The Organization will revise its internal process to include a dual-review system. Two designated staff members will now be cross-trained and authorized to review and certify Financial Requests for Payment to ensure timeliness. A formal submission calendar will be developed, including internal deadlines that precede the agency's due dates by a minimum of five business days.
Assistance Listing, Federal Agency, and Program Name 97.039, Hazard Mitigation Grant Program
Federal Award Identification Number and Year 4394-31, 2024
Pass through Entity South Carolina Emergency Management Division
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria In accordance with 2 CFR section 200.302(b)(6), all non federal entities must establish written procedures to implement the cash management requirements of 2 CFR section 200.305.
Condition The Organization did not have a formal cash management policy in place for the period under audit.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context After discussion with management, it was identified that the organization does not maintain a formal cash management policy.
Cause and Effect There is not an established control to ensure that a written policy is in place. Because there is no written policy, the Organization is not in compliance with 2 CFR 200.302(b)(6).
Recommendation We recommend that the Organization implement a formal cash management policy and that controls are implemented to ensure that it is maintained and updated, as necessary.
Views of Responsible Officials and Planned Corrective Actions The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025.
Assistance Listing, Federal Agency, and Program Name 97.039, Hazard Mitigation Grant Program
Federal Award Identification Number and Year 4394-31, 2024
Pass through Entity South Carolina Emergency Management Division
Finding Type Material weakness
Repeat Finding No
Criteria The Schedule of Expenditures of Federal Awards should include all expenditures associated with federal grants during the fiscal year and there should be controls to ensure no double dipping of expenditures across federal grants.
Condition The Organization did not capture certain Hazard Mitigation Grant funding that was expended in a previous period on the SEFA and did not effectively apply controls to ensure expenditures are tracked to a unique grant in a proper period.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context The Organization improperly excluded $1,974,294 of expenditures related to the Hazard Mitigation Grant Program from the September 30, 2023 Schedule of Expenditures of Federal Awards. The Organization also did not apply appropriate controls to ensure expenditures are tracked to a unique grant in a proper period.
Cause and Effect The Organization does not have an award management system connected to their accounting software to appropriately track federal grants and their associated expenditures. This prevented the Organization from being able to implement effective controls to validate expenditures were applied to the proper grant in the proper period. This also resulted in the Organization having an incomplete SEFA for the fiscal year ended September 30, 2023.
Recommendation Our recommendation is that the organization implements a centralized grants management system that is linked to the accounting system to clearly link expenditures to their corresponding federal award.
Views of Responsible Officials and Planned Corrective Actions The Organization will implement a centralized grant tracking log within the financial system that uniquely identifies each federal grant and records expenditures by program and fiscal year.
The Organization will conduct annual cross-departmental training on SEFA reporting requirements, emphasizing the importance of accurate and timely classification of federal expenditures.
The Organization will require quarterly reconciliations between grant activity logs and the general ledger to validate completeness and timing accuracy before SEFA preparation.
Assistance Listing, Federal Agency, and Program Name 93.870, Maternal, Infant, and Early Childhood Home Visiting Grant
Federal Award Identification Number and Year S MIEC F 2022 9 2, 2024
Pass through Entity Children's Trust of South Carolina
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria Expenditures should be approved, following the Organization's policies and procedures, and incurred before requesting reimbursement to ensure costs are allowable under the Program.
Condition The Organization had a control in place to approve contractor expenditures prior to charging the expense to the Program; however, the control was ineffective and resulted in a cost being requested for reimbursement that had not been incurred by the Organization.
Questioned Costs $1,667
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed The questioned costs total the amount of the invoiced identified as unallowable.
Context Out of a sample of 40 expenses, we identified one expense that was not appropriately approved by the Organization's control processes and was not paid for.
Cause and Effect The Organization's control over contractor payments was not designed effectively to ensure costs were approved and incurred prior to requesting reimbursement. The failure to have an effective control in place caused the Organization to charge a cost to the Program that the Organization had not yet incurred.
Recommendation We recommend that the review process ensure that items have been expended prior to charging the amount to the grant.
Views of Responsible Officials and Planned Corrective Actions The Organization will implement a mandatory documentation checklist, including verified contractor invoices and proof of service completion, prior to approving any expense charged to the Program.
The Organization will adopt a two-level approval process—requiring sign-off by both the Program Manager and the Finance Department to validate incurred costs.
Assistance Listing, Federal Agency, and Program Name 93.870, Maternal, Infant, and Early Childhood Home Visiting Grant
Federal Award Identification Number and Year S MIEC F 2022 9 2, 2024
Pass through Entity Children's Trust of South Carolina
Finding Type Material weakness
Repeat Finding No
Criteria Per the award agreement, awardees are required to submit Financial Request for Payments (FRP) at least quarterly by the end of the month following the month to be invoiced.
Condition The Organization had a control to review and certify the Financial Request for Payment; however, the control was ineffective and resulted in untimely submission of the request to the awarding agency.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context Out of a sample of eight Financial Requests for Payment, we identified one that was not certified or submitted within the required timeframe. The FRP was certified one day after the submission deadline and submitted five days after the submission deadline.
Cause and Effect The Organization designed controls related to reviewing and certifying the FRPs; however, the review process did not ensure that requests were submitted on time. The failure to have an effective control in place caused the Organization to not meet the submission date.
Recommendation We recommend that the review process include procedures to ensure prompt submission to meet the reporting requirements associated with the award.
Views of Responsible Officials and Corrective Action Plan The Organization will revise its internal process to include a dual-review system. Two designated staff members will now be cross-trained and authorized to review and certify Financial Requests for Payment to ensure timeliness. A formal submission calendar will be developed, including internal deadlines that precede the agency's due dates by a minimum of five business days.
Assistance Listing, Federal Agency, and Program Name 97.039, Hazard Mitigation Grant Program
Federal Award Identification Number and Year 4394-31, 2024
Pass through Entity South Carolina Emergency Management Division
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria In accordance with 2 CFR section 200.302(b)(6), all non federal entities must establish written procedures to implement the cash management requirements of 2 CFR section 200.305.
Condition The Organization did not have a formal cash management policy in place for the period under audit.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context After discussion with management, it was identified that the organization does not maintain a formal cash management policy.
Cause and Effect There is not an established control to ensure that a written policy is in place. Because there is no written policy, the Organization is not in compliance with 2 CFR 200.302(b)(6).
Recommendation We recommend that the Organization implement a formal cash management policy and that controls are implemented to ensure that it is maintained and updated, as necessary.
Views of Responsible Officials and Planned Corrective Actions The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025.
Assistance Listing, Federal Agency, and Program Name 97.039, Hazard Mitigation Grant Program
Federal Award Identification Number and Year 4394-31, 2024
Pass through Entity South Carolina Emergency Management Division
Finding Type Material weakness
Repeat Finding No
Criteria The Schedule of Expenditures of Federal Awards should include all expenditures associated with federal grants during the fiscal year and there should be controls to ensure no double dipping of expenditures across federal grants.
Condition The Organization did not capture certain Hazard Mitigation Grant funding that was expended in a previous period on the SEFA and did not effectively apply controls to ensure expenditures are tracked to a unique grant in a proper period.
Questioned Costs None
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed N/A
Context The Organization improperly excluded $1,974,294 of expenditures related to the Hazard Mitigation Grant Program from the September 30, 2023 Schedule of Expenditures of Federal Awards. The Organization also did not apply appropriate controls to ensure expenditures are tracked to a unique grant in a proper period.
Cause and Effect The Organization does not have an award management system connected to their accounting software to appropriately track federal grants and their associated expenditures. This prevented the Organization from being able to implement effective controls to validate expenditures were applied to the proper grant in the proper period. This also resulted in the Organization having an incomplete SEFA for the fiscal year ended September 30, 2023.
Recommendation Our recommendation is that the organization implements a centralized grants management system that is linked to the accounting system to clearly link expenditures to their corresponding federal award.
Views of Responsible Officials and Planned Corrective Actions The Organization will implement a centralized grant tracking log within the financial system that uniquely identifies each federal grant and records expenditures by program and fiscal year.
The Organization will conduct annual cross-departmental training on SEFA reporting requirements, emphasizing the importance of accurate and timely classification of federal expenditures.
The Organization will require quarterly reconciliations between grant activity logs and the general ledger to validate completeness and timing accuracy before SEFA preparation.
Assistance Listing, Federal Agency, and Program Name 93.870, Maternal, Infant, and Early Childhood Home Visiting Grant
Federal Award Identification Number and Year S MIEC F 2022 9 2, 2024
Pass through Entity Children's Trust of South Carolina
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria Expenditures should be approved, following the Organization's policies and procedures, and incurred before requesting reimbursement to ensure costs are allowable under the Program.
Condition The Organization had a control in place to approve contractor expenditures prior to charging the expense to the Program; however, the control was ineffective and resulted in a cost being requested for reimbursement that had not been incurred by the Organization.
Questioned Costs $1,667
If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A
Identification of How Questioned Costs Were Computed The questioned costs total the amount of the invoiced identified as unallowable.
Context Out of a sample of 40 expenses, we identified one expense that was not appropriately approved by the Organization's control processes and was not paid for.
Cause and Effect The Organization's control over contractor payments was not designed effectively to ensure costs were approved and incurred prior to requesting reimbursement. The failure to have an effective control in place caused the Organization to charge a cost to the Program that the Organization had not yet incurred.
Recommendation We recommend that the review process ensure that items have been expended prior to charging the amount to the grant.
Views of Responsible Officials and Planned Corrective Actions The Organization will implement a mandatory documentation checklist, including verified contractor invoices and proof of service completion, prior to approving any expense charged to the Program.
The Organization will adopt a two-level approval process—requiring sign-off by both the Program Manager and the Finance Department to validate incurred costs.