Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Material Weakness
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Material Weakness
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002)
Significant Deficiency
Criteria:
In accordance with Federal Acquisition Regulation (FAR) Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of Department of Health and Human Services (DHHS) Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)."
Condition:
During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to identify, mark, record, or maintain equipment. The Coalition also does not have sufficiently established control policies for an annual inventory.
Effect:
The Coalition does not have the ability to discern "Government Property" from other property. The Coalition at any time is unaware if "Government Property" is misplaced or stolen.
Recommendation:
We recommend the Coalition becomes familiar with requirements of FAR Contact Clause 52.245-1 "Government Property" and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition schedule and perform an annual inventory of property being purchased with federal funds.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002)
Significant Deficiency
Criteria:
In accordance with Federal Acquisition Regulation (FAR) Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of Department of Health and Human Services (DHHS) Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)."
Condition:
During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to identify, mark, record, or maintain equipment. The Coalition also does not have sufficiently established control policies for an annual inventory.
Effect:
The Coalition does not have the ability to discern "Government Property" from other property. The Coalition at any time is unaware if "Government Property" is misplaced or stolen.
Recommendation:
We recommend the Coalition becomes familiar with requirements of FAR Contact Clause 52.245-1 "Government Property" and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition schedule and perform an annual inventory of property being purchased with federal funds.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003)
Criteria:
Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible.
Condition:
During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal funds.
Questioned Costs:
None
Cause:
The Coalition has not entered into a cash collateralization agreement with their financial institution.
Effect:
The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure.
Recommendation:
We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003)
Criteria:
Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible.
Condition:
During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal funds.
Questioned Costs:
None
Cause:
The Coalition has not entered into a cash collateralization agreement with their financial institution.
Effect:
The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure.
Recommendation:
We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004)
Criteria:
In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327.
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327.
Questioned Costs:
None
Cause:
The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327.
Effect:
The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004)
Criteria:
In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327.
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327.
Questioned Costs:
None
Cause:
The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327.
Effect:
The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Material Weakness
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Material Weakness
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002)
Significant Deficiency
Criteria:
In accordance with Federal Acquisition Regulation (FAR) Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of Department of Health and Human Services (DHHS) Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)."
Condition:
During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to identify, mark, record, or maintain equipment. The Coalition also does not have sufficiently established control policies for an annual inventory.
Effect:
The Coalition does not have the ability to discern "Government Property" from other property. The Coalition at any time is unaware if "Government Property" is misplaced or stolen.
Recommendation:
We recommend the Coalition becomes familiar with requirements of FAR Contact Clause 52.245-1 "Government Property" and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition schedule and perform an annual inventory of property being purchased with federal funds.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002)
Significant Deficiency
Criteria:
In accordance with Federal Acquisition Regulation (FAR) Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of Department of Health and Human Services (DHHS) Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)."
Condition:
During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to identify, mark, record, or maintain equipment. The Coalition also does not have sufficiently established control policies for an annual inventory.
Effect:
The Coalition does not have the ability to discern "Government Property" from other property. The Coalition at any time is unaware if "Government Property" is misplaced or stolen.
Recommendation:
We recommend the Coalition becomes familiar with requirements of FAR Contact Clause 52.245-1 "Government Property" and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition schedule and perform an annual inventory of property being purchased with federal funds.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003)
Criteria:
Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible.
Condition:
During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal funds.
Questioned Costs:
None
Cause:
The Coalition has not entered into a cash collateralization agreement with their financial institution.
Effect:
The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure.
Recommendation:
We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003)
Criteria:
Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible.
Condition:
During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal funds.
Questioned Costs:
None
Cause:
The Coalition has not entered into a cash collateralization agreement with their financial institution.
Effect:
The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure.
Recommendation:
We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004)
Criteria:
In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327.
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327.
Questioned Costs:
None
Cause:
The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327.
Effect:
The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004)
Criteria:
In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327.
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327.
Questioned Costs:
None
Cause:
The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327.
Effect:
The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.