Criteria: The Company should must establish and maintain effective internal control over federal awards to provide reasonable assurance that the award is managed in compliance with federal statutes, regulations, and the terms and conditions of the award. Adequate documentation must be maintained to support internal control activities and compliance with federal requirements. Statement of Condition: During our walkthroughs and substantive testing, supporting documentation was not available to allow us to evaluate whether required internal controls were performed. The documents were unavailable due to the expiration of the entity’s document retention period and employee turnover, which resulted in the loss of institutional knowledge about the controls performed during the award period. Because the requested documentation could not be provided, we were unable to verify the performance or effectiveness of internal controls related to the compliance requirement tested. Cause of Condition: The entity did not maintain documentation of internal control activities beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for testing internal controls over federal awards were no longer available. Effect of Condition: Due to the absence of supporting documentation, we were unable to determine whether internal controls over the compliance requirement were properly designed and operating effectively. This results in the inability to test internal controls and assess control risk at a “low” level. Recommendation: We recommend that management (1) strengthen record retention practices to ensure that documentation of internal control activities is preserved in accordance with 2 CFR 200.334 and is available for future audits, (2) implement procedures to maintain institutional knowledge, particularly during periods of employee turnover (e.g., documented policies, cross-training, centralized recordkeeping), and (3) consider extending retention periods for documents supporting high-risk federal programs or key internal control activities. Management should ensure documentation is sufficient to demonstrate compliance and support internal control operations. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under the Uniform Guidance, costs charged to a federal program must be allowable, reasonable, allocable, and properly documented, expenditures must be for activities permitted under the federal program, and costs must be incurred within the approved period of performance. Entities must maintain sufficient source documentation to support changes to federal awards. Statement of Condition: During our testing over compliance of allowable activities, allowable costs, and period of performance, supporting invoices or similar documentation was not available for 7 out of 10 expenditures tested. As a result, we were unable to validate whether the costs were allowable under the program, whether the activities were allowable, whether the costs were incurred within the approved period of performance, and whether the expenditures were reasonable and properly supported. Cause of Condition: The entity did not maintain supporting documentation beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for testing compliance of allowable activities, allowable costs, and period of performance were not available. Effect of Condition: Because invoices or similar documentation was unavailable for the majority of expenditures tested, we were unable to determine if the costs were allowable or incurred within the period of performance, therefore there is a risk of unallowable or unsupported costs being charged to the award, and the entity is not in compliance with federal documentation and cost principles requirements. Questioned Costs: Questioned costs total $129,232, representing the unsupported portion of the 7 out of 10 expenditures for which documentation could not be provided. Recommendation: We recommend that management (1) strengthen internal controls over documentation retention and expenditure support, (2) implement centralized and consistent procedures for retaining invoices and supporting records, (3) conduct periodic internal reviews to ensure all costs charged to federal awards are adequately supported, and (4) provide training to staff responsible for grant accounting to ensure understanding of federal documentation requirements. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under the Uniform Guidance only allowable costs incurred during the approved period of performance may be charged to a federal award. Costs incurred before or after the award period are unallowable unless specifically authorized by the federal agency. Statement of Condition: During our testing over compliance of period of performance, we noted 1 out of 10 expenditures tested was incurred after the award’s period of performance had ended. The invoice date of November 13, 2019 exceeded the period of performance end date of August 31, 2019, resulting in an unallowable charge to the federal award. Cause of Condition: The entity did not have sufficient controls in place to verify that costs were incurred within the authorized performance period before being charged to the federal award. Contributing factors included inadequate review procedures during invoice processing. Effect of Condition: Charging costs incurred after the period of performance resulted in unallowable costs being charged to the award and noncompliance with federal requirements. Questioned Costs: Questioned costs total $2,432, representing the full amount of expenditure incurred after the period of performance for 1 of 10 expenditures selections. Recommendation: We recommend that management (1) implement or strengthen review procedures to ensure all costs charged to federal awards are incurred within the approved performance period, (2) train personnel responsible for grant accounting on the importance of verifying dates of service, invoice dates, and award period limitations, and (3) consider implementing system-based controls that prevent posting expenditures with dates outside the award period. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under 2 CFR 200.512(a), an auditee must submit the single audit reporting package, including financial statements and the schedule of expenditures of federal awards (SEFA), no later than 30 days after receipt of the auditor’s report or nine months after the fiscal year-end, whichever comes first. Company management is responsible for ensuring the financial statements are prepared and issued timely to meet the Single Audit submission deadline established by the Federal Audit Clearinghouse (FAC). Statement of Condition: The auditee’s single audit financial statements were not issued by the required due date. The fiscal year ended on December 31, 2019, making the reporting package due no later than September 30, 2020. However, the audit report date is December 17, 2025, resulting in the late submission of the Single Audit reporting package to the FAC. Additionally, the audit reports for the years ended December 31, 2020 to 2024 have not yet been issued. Cause of Condition: The delay occurred because of employee turnover and lack of adequate internal controls over financial reporting timelines. The auditee did not have sufficient processes in place to ensure the timely preparation and issuance of financial statements. Effect of Condition: Because the financial statements and reporting package were issued late the auditee failed to comply with federal reporting requirements, federal agencies and pass-through entities did not receive timely financial and compliance information needed for monitoring and oversight, and the delay increases the risk that financial reporting issues may go undetected or unresolved. Questioned Costs: None. Recommendation: We recommend that management (1) strengthen internal controls over year-end financial reporting to ensure timely completion of the audit, (2) implement a detailed closing schedule and tracking process to monitor deadlines, (3) ensure adequate staffing or external support during the financial statement preparation and audit process, and (4) conduct periodic reviews to confirm compliance with federal Single Audit submission deadlines. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under Uniform Guidance and the terms and conditions of the federal award, the auditee must maintain records sufficient to detail the financial and programmatic activities of the award, including support for required monthly reports. Statement of Condition: During testing of compliance over reporting, the Company was unable to provide monthly reporting supporting documentation for 1 out of 2 months tested. The documents were unavailable due to the expiration of the entity’s document retention period and employee turnover, which resulted in the loss of institutional knowledge about the controls performed during the award period. As a result, we were not able to verify the accuracy, completeness, or review of the reported information for that month. Cause of Condition: The entity did not maintain documentation of internal control activities beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for compliance over reporting of federal awards were no longer available. Effect of Condition: As a result of the missing support, the Company is not in compliance with federal documentation requirements and award terms, we were unable to confirm the accuracy and completeness of the reported information for 1 out of 2 months selected for testing, and there is an increased risk that errors or misstatements in program reporting may go undetected. Questioned Costs: None. Recommendation: We recommend that management (1) strengthen internal controls over monthly reporting to ensure all supporting documentation is consistently retained, (2) centralize the retention of monthly reporting support in accordance with federal recordkeeping requirements, (3) provide staff training on reporting requirements and documentation expectations under the award, and (4) implement periodic internal reviews to verify that documentation is complete before reports are submitted. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under Uniform Guidance and an entity must verify that subrecipients meet eligibility requirements established by the federal program, applicable regulations, and term and conditions of the award, maintain documentation to support subrecipient eligibility determinations, and ensure that subawards are issued only to eligible entities. Statement of Condition: During testing of compliance of eligibility, the Company was unable to provide documentation evidencing which subrecipients were approved under the contract due to the expiration of the entity’s document retention period and employee turnover, which resulted in the loss of institutional knowledge about the controls performed during the award period. Cause of Condition: The entity did not maintain documentation of subrecipient eligibility beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for compliance over eligibility of federal awards were no longer available. Effect of Condition: As a result of the missing documentation, the auditee is not in compliance with federal requirements related to subrecipient eligibility, there is an increased risk that funds may have been awarded to ineligible subrecipients, the pass-through entity cannot demonstrate that it carried out required oversight responsibilities under the Uniform Guidance, and eligibility errors may go unidentified, increasing the risk of future noncompliance. Questioned Costs: Questioned costs total $213,005, representing the subawards where documentation of eligibility could not be provided. Recommendation: We recommend that management (1) implement formal procedures for reviewing and documenting subrecipient eligibility prior to awarding funds, (2) develop a standardized eligibility checklist and require supporting documentation to be retained in a centralized file, (3) provide training to grants management staff on Uniform Guidance eligibility requirements, and (4) periodically monitor subrecipient files to ensure eligibility documentation is complete and retained in accordance with Uniform Guidance. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
Criteria: Under Uniform Guidance, pass-through entities must monitor subrecipients to ensure compliance with federal program requirement, review financial and performance reports submitted by subrecipients, and ensure that subaward expenditures are supported and allowable before including them in reimbursement requests to the pass-through entity. Under 2 CFR 200.302(b) and 2 CFR 200.403(g), non-federal entities must maintain adequate documentation to support all costs charged to federal awards, including amounts reimbursed through subaward arrangements. Statement of Condition: During our testing over the subrecipient monitoring compliance requirement, we noted that although the Company was able to provide documentation supporting certain subaward expenditures, the Company was unable to provide documentation that reconciled or agreed to the specific amounts submitted to RIDOH for reimbursement. As a result, we were unable to verify that the subaward expenditures included in the reimbursement requests were fully supported by underlying subrecipient records and that they were appropriately monitored prior to submission. Cause of Condition: The entity did not maintain documentation of internal control activities beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for compliance over subrecipient monitoring of federal awards were no longer available. Effect of Condition: Because the support for subaward expenditures did not agree to the amounts submitted to RIDOH the Company is not in compliance with subrecipient monitoring requirements under Uniform Guidance, there is an increased risk that unallowable, inaccurate, or unsupported subrecipient costs may be included in reimbursement requests, RIDOH does not have adequate assurance that the Company performed required oversight of subrecipient financial activity, and unsupported reimbursement amounts may be subject to recovery by the pass-through entity. Questioned Costs: Questioned costs total $127,813, representing the total subawards where documentation of subrecipient monitoring could not be provided. Recommendation: We recommend that management (1) strengthen subrecipient monitoring controls to ensure subrecipient expenditures are reconciled to reimbursement request amounts, (2) implement a standardized reconciliation process and maintain supporting documentation in a centralized location, (3) train staff involved in subrecipient monitoring and reimbursement submissions on Uniform Guidance requirements, and (4) perform periodic internal reviews to ensure compliance and documentation completeness. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.