2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.
2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐006 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that costs reimbursed
under federal programs are in accordance with 2 CFR Part 200, Subpart E.
Condition ‐ We reviewed the supporting documentation for a sample of the expenditures
reimbursed under the federal grant for the remodel project. This included supporting
documentation for the amount and allowability under the grant. It was determined that two
expenditures were for another grant, one expenditure was paid from an estimate, and six
expenditures were for expenses not included in the grant proposal.
Cause ‐ During the course of our engagement, we noted that internal controls were not
adequately designed to allow for the compliance with Uniform Guidance.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 9 out
of the 46 transactions were not in accordance with Subpart E of Uniform Guidance. These
transactions totaled $24,913 of $3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are handled appropriately under Uniform Guidance, Subpart #.
Views of Responsible Officials ‐ Management is in agreement with this finding.
Repeat Finding – This is a new finding.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐007 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Significant Deficiency in Internal Control over Compliance
Criteria ‐ A good system of internal controls includes a process to ensure that proper approvals
are obtained relating to costs under the program.
Condition ‐ We noted that the Organization’s internal controls did not have adequate internal
controls to ensure costs are properly approved. Cause ‐ During the course of our engagement, we noted that two costs under the program were
not formally approved.
Effect ‐ The Organization’s internal controls failed to formally approve costs under the program.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ A nonstatistical sample of 46 costs were selected for expense testing. 2 out
of the 46 transactions did not have formal approval. These transactions totaled $400 of
$3,274,092 costs tested.
Recommendation ‐ Management should implement internal controls to ensure all costs under
the program are formally approved.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-006.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐008 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Allowable Costs and Allowable Activities
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200, Subpart E requires that all expenses reimbursed
under the Uniform Guidance be adequately documented.
Condition ‐ We requested supporting schedules for all expenditures reimbursed under the
federal program. For the expenditures reimbursed under the COVID-19 Fiscal Recovery
program and the funding awarded for the Silver Linings building project. A listing of specific
expenditures for these programs was not available for our testing procedures.
Cause ‐ The Organization did not have proper procedures to ensure tracking of expenditure
submitted for reimbursement.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ $239,614
Context/Sampling ‐ No sampling was performed as a listing of expenditures was not available
for testing.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper tracking of all expenditures reimbursed under federal programs.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a new finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐009 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must use its own documented procurement procedures which
reflect applicable state and local laws and regulations, provided that the procurements conform
to applicable federal law and standards.
Condition ‐ Procurement policies were not updated to conform to applicable standards under
Uniform Guidance.
Cause ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance relating to
suspended and debarred vendors.
Effect ‐ The Organization did not have proper procedures to ensure its procurement policies
were updated to conform to the requirements identified in Uniform Guidance.
Questioned Costs ‐ None Reported.
Context/Sampling ‐ No sampling was performed as the procurement policy was examined in its
entirety.
Repeat Finding – This is a repeat finding of 2022-007.
Recommendation ‐ We recommend the Organization ensures its procurement policies are
updated to conform to the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐010 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Procurement, Suspension, and Debarment
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
requires that a non‐Federal entity must follow procurement procedures which reflect applicable
state and local laws and regulations, provided that the procurements conform to applicable
federal law and standards.
Condition ‐ Procurement policies under Uniform Guidance were not followed when obtaining
bids for two contracts. Cause ‐ Due to grant timing restraints, the Organization did not follow proper procurement
procedures for obtaining bids for two contracts under Uniform Guidance.
Effect ‐ The Organization did not have proper procedures to ensure procurement compliance
requirements under Uniform Guidance were followed when obtaining bids for contracts.
Questioned Costs ‐ $3,227,905
Context/Sampling ‐ A nonstatistical sample of 2 contracts were selected for testing. 2 out of the
2 contracts did not follow procurement compliance requirements. These transactions totaled
$3,227,905 of $3,274,092 costs tested.
Recommendation ‐ We recommend the Organization follow applicable procurement policies
under the requirements identified in Uniform Guidance.
Views of Responsible Officials ‐ Management is in agreement with the finding.
Repeat Finding – This is a repeat finding of 2022-008.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.
2023‐011 Department of Treasury
Federal Financial Assistance Listing/ALN 21.027
COVID‐19 Coronavirus State and Local Fiscal Recovery Funds
Reporting
Material Noncompliance and Material Weakness in Internal Control over Compliance
Criteria ‐ In accordance with 2 CFR Part 200.328 and 31 CFR Section 354(c), the federal
program requires quarterly and annual project and expenditure reporting be submitted to the
granting oversight agency.
Condition ‐ We requested copies of the submitted reports and supporting documentation for the
year under audit in order to perform the compliance testing. These items could not be
reproduced to verify that the reporting was submitted as required under the audit.
Cause ‐ The Organization did not have proper procedures to ensure preparation and
submission of the required reporting under the federal award.
Effect ‐ The deficiency in internal controls resulted in material noncompliance to the
Organization.
Questioned Costs ‐ None reported.
Context/Sampling ‐ No sampling was performed as supporting documentation to allow for
testing of the reporting requirement was unavailable.
Recommendation ‐ We recommend the Organization update its policies and procedures to allow
for the proper identification of all reporting requirements, preparation and review of reports to be
submitted, and accumulation of appropriate supporting documentation and schedules.
Views of Responsible Officials ‐ Management is in agreement with the finding. Repeat Finding – This is a not a repeat finding.