Finding 2023-003
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023
Compliance Requirement: Equipment and Real Property Management
Repeat Finding: No
Condition: The Organization did not separately identify and track capital asset activity funded with federal grants.
Questioned Costs: None
Context: For the one sampled capital asset purchase, funded with this federal grant, no identifying or tracking
method was used on the capital asset listing.
Criteria: Per 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements
(Uniform Guidance), Section 200.313 Equipment, "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1))."
Cause: The grantor did not communicate this requirement in the grant award document.
Effect: The identification of federally-funded capital assets allows for an organization to manage the asset
throughout its useful life until disposition, when the federal grantor may be owed a portion of the proceeds of sale.
Recommendation: We recommend a policy be developed that would include procedures for identifying and
tracking capital assets funded with federal grants. This could include identification in a capital asset listing or using a tracking mechanism.
Finding 2023-004
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Suspension and Debarment
Repeat Finding: No
Condition: During our testing of three covered transactions (all vendors), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity.
Questioned Costs: None
Context: The finding was noted for two of two vendors tested for 59.059 and the one vendor tested for 21.027.
Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the Organization can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract.
Cause: Federal grants were new to the Organization and the required suspension and debarment checks were not done timely.
Effect: The finding indicates that there could be some process improvements in how contracts are reviewed,
documented and maintained to provide evidence the compliance requirements are being met.
Recommendation: We recommend that the Organization either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that Organization has proper procedures in place to ensure that all contractual documentation is maintained and able to be located.
Finding 2023-005
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Financial Reporting
Repeat Finding: Yes
Condition: Three grant reports lacked documentation of a detailed review by someone other than the preparer of the federal reports.
Questioned Costs: None
Context: The finding is noted for two of the two Quarterly Progress Reports tested for 21.027 and the one SF 425
Federal Financial Report tested for 59.059.
Criteria: All federal grant reports should be documented as being reviewed by a person knowledgeable about the requirements for activities allowed or unallowed for the grant. As such, the Organization’s internal control over this process should ensure all expenditures are reviewed by a person with such knowledge.
Cause: Controls in place are not sufficient to ensure completeness and accuracy of the reports submitted to granting agencies.
Effect: Without proper controls in place, expenditures may not be complete, accurate or allowable under grant
requirements and could result in unallowable federal expenditures reported.
Recommendation: We recommend the Organization retain documentation of a knowledgeable person separate
from the preparer of the reports to review all expenditures that go into the reports prior to submission.
Finding 2023-004
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Suspension and Debarment
Repeat Finding: No
Condition: During our testing of three covered transactions (all vendors), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity.
Questioned Costs: None
Context: The finding was noted for two of two vendors tested for 59.059 and the one vendor tested for 21.027.
Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the Organization can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract.
Cause: Federal grants were new to the Organization and the required suspension and debarment checks were not done timely.
Effect: The finding indicates that there could be some process improvements in how contracts are reviewed,
documented and maintained to provide evidence the compliance requirements are being met.
Recommendation: We recommend that the Organization either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that Organization has proper procedures in place to ensure that all contractual documentation is maintained and able to be located.
Finding 2023-005
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Financial Reporting
Repeat Finding: Yes
Condition: Three grant reports lacked documentation of a detailed review by someone other than the preparer of the federal reports.
Questioned Costs: None
Context: The finding is noted for two of the two Quarterly Progress Reports tested for 21.027 and the one SF 425
Federal Financial Report tested for 59.059.
Criteria: All federal grant reports should be documented as being reviewed by a person knowledgeable about the requirements for activities allowed or unallowed for the grant. As such, the Organization’s internal control over this process should ensure all expenditures are reviewed by a person with such knowledge.
Cause: Controls in place are not sufficient to ensure completeness and accuracy of the reports submitted to granting agencies.
Effect: Without proper controls in place, expenditures may not be complete, accurate or allowable under grant
requirements and could result in unallowable federal expenditures reported.
Recommendation: We recommend the Organization retain documentation of a knowledgeable person separate
from the preparer of the reports to review all expenditures that go into the reports prior to submission.
Finding 2023-003
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023
Compliance Requirement: Equipment and Real Property Management
Repeat Finding: No
Condition: The Organization did not separately identify and track capital asset activity funded with federal grants.
Questioned Costs: None
Context: For the one sampled capital asset purchase, funded with this federal grant, no identifying or tracking
method was used on the capital asset listing.
Criteria: Per 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements
(Uniform Guidance), Section 200.313 Equipment, "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1))."
Cause: The grantor did not communicate this requirement in the grant award document.
Effect: The identification of federally-funded capital assets allows for an organization to manage the asset
throughout its useful life until disposition, when the federal grantor may be owed a portion of the proceeds of sale.
Recommendation: We recommend a policy be developed that would include procedures for identifying and
tracking capital assets funded with federal grants. This could include identification in a capital asset listing or using a tracking mechanism.
Finding 2023-004
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Suspension and Debarment
Repeat Finding: No
Condition: During our testing of three covered transactions (all vendors), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity.
Questioned Costs: None
Context: The finding was noted for two of two vendors tested for 59.059 and the one vendor tested for 21.027.
Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the Organization can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract.
Cause: Federal grants were new to the Organization and the required suspension and debarment checks were not done timely.
Effect: The finding indicates that there could be some process improvements in how contracts are reviewed,
documented and maintained to provide evidence the compliance requirements are being met.
Recommendation: We recommend that the Organization either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that Organization has proper procedures in place to ensure that all contractual documentation is maintained and able to be located.
Finding 2023-005
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Financial Reporting
Repeat Finding: Yes
Condition: Three grant reports lacked documentation of a detailed review by someone other than the preparer of the federal reports.
Questioned Costs: None
Context: The finding is noted for two of the two Quarterly Progress Reports tested for 21.027 and the one SF 425
Federal Financial Report tested for 59.059.
Criteria: All federal grant reports should be documented as being reviewed by a person knowledgeable about the requirements for activities allowed or unallowed for the grant. As such, the Organization’s internal control over this process should ensure all expenditures are reviewed by a person with such knowledge.
Cause: Controls in place are not sufficient to ensure completeness and accuracy of the reports submitted to granting agencies.
Effect: Without proper controls in place, expenditures may not be complete, accurate or allowable under grant
requirements and could result in unallowable federal expenditures reported.
Recommendation: We recommend the Organization retain documentation of a knowledgeable person separate
from the preparer of the reports to review all expenditures that go into the reports prior to submission.
Finding 2023-004
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Suspension and Debarment
Repeat Finding: No
Condition: During our testing of three covered transactions (all vendors), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity.
Questioned Costs: None
Context: The finding was noted for two of two vendors tested for 59.059 and the one vendor tested for 21.027.
Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the Organization can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract.
Cause: Federal grants were new to the Organization and the required suspension and debarment checks were not done timely.
Effect: The finding indicates that there could be some process improvements in how contracts are reviewed,
documented and maintained to provide evidence the compliance requirements are being met.
Recommendation: We recommend that the Organization either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that Organization has proper procedures in place to ensure that all contractual documentation is maintained and able to be located.
Finding 2023-005
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury
Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 –
3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22-
BASE-BTBC, Award Period 6/16/2022 – 6/15/2024
Compliance Requirement: Financial Reporting
Repeat Finding: Yes
Condition: Three grant reports lacked documentation of a detailed review by someone other than the preparer of the federal reports.
Questioned Costs: None
Context: The finding is noted for two of the two Quarterly Progress Reports tested for 21.027 and the one SF 425
Federal Financial Report tested for 59.059.
Criteria: All federal grant reports should be documented as being reviewed by a person knowledgeable about the requirements for activities allowed or unallowed for the grant. As such, the Organization’s internal control over this process should ensure all expenditures are reviewed by a person with such knowledge.
Cause: Controls in place are not sufficient to ensure completeness and accuracy of the reports submitted to granting agencies.
Effect: Without proper controls in place, expenditures may not be complete, accurate or allowable under grant
requirements and could result in unallowable federal expenditures reported.
Recommendation: We recommend the Organization retain documentation of a knowledgeable person separate
from the preparer of the reports to review all expenditures that go into the reports prior to submission.