Audit 377852

Section III – Major Federal Awards Programs – Findings and Questioned Costs Finding 2024-006: Activities Allowed or Unallowed / Allowable Costs - Inadequate Chart of Accounts Segregation for Unallowable Costs (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: Under 2 CFR 200.302(b)(3), non-Federal entities must maintain records that adequately identify the source and application of funds and must segregate unallowable costs to ensure compliance with cost principles. Condition: The chart of accounts does not sufficiently segregate unallowable costs from allowable program expenditures. Certain unallowable expenditures were coded to general operating accounts without clear differentiation. Cause: The Center lacks a detailed coding structure and written policies requiring explicit identification and segregation of unallowable costs. Effect: There is increased risk that unallowable costs could be charged to Federal awards, leading to potential noncompliance, questioned costs, or improper reimbursement requests. Recommendation: Management should implement a revised chart of accounts that clearly differentiates allowable vs. unallowable costs, supported by updated written policies and staff training. Repeat Finding: This is not a repeat finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-007: Activities Allowed or Unallowed / Allowable Costs - Insufficient Budget-to-Actual Reviews (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: Under 2 CFR 200.302(b)(5) and established internal control frameworks such as COSO, entities must compare actual expenditures to budgeted amounts to ensure proper financial management and compliance with award terms. Condition: Budget-to-actual analyses were not consistently performed or documented for certain Federal programs. Cause: The Center lacks a formalized review schedule and adequate documentation procedures. Effect: Failure to identify variances may result in overspending, underspending, or misclassification of Federal program costs. Recommendation: Management should implement formal, periodic budget-to-actual reviews supported by standardized documentation requirements. Repeat Finding: This is not a repeat finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-008: Cash Management - Inadequate Authorization and Supporting Documentation for Reimbursement Requests (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: 2 CFR 200.415(a) requires that financial reports and reimbursement requests be certified as accurate and complete. Strong internal controls require appropriate documentation supporting all drawdown requests. Condition: Reimbursement requests lacked evidence of supervisory approval and did not consistently include required supporting documentation. Cause: A standardized approval workflow for reimbursement and drawdown requests has not been established. Effect: Inadequate documentation increases the risk of inaccurate reimbursement requests, which may result in disallowed costs or repayment obligations. Recommendation: Management should develop and implement a formal approval process requiring supervisor sign-off and attachment of all required supporting documentation prior to submission. Repeat Finding: This is not a repeat finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-009: Eligibility - Lack of Segregation of Duties in Expenditure Determination and Approval (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: As per 2 CFR 200.303(a), entities must maintain effective internal controls, including segregation of duties, to prevent unauthorized or inaccurate transactions. Condition: The same individual was responsible for determining expenditure allowability and approving expenditures for reimbursement. Cause: Staffing limitations and the absence of written policies resulting in inadequate role separation. Effect: Insufficient segregation of duties increases the risk of errors or inappropriate expenditures. Recommendation: Management should reassign roles so that expenditure allowability reviews and expenditure approvals are performed by separate individuals. If staffing is limited, implement compensating management review controls. Repeat Finding: This is not a repeat finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-010: Cash Management - Inadequate Policies for Drawdowns, Program Income, and Reconciliations (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: 2 CFR 200.305 requires documented procedures for cash management, including drawdowns, program income usage, and reconciliation processes. Condition: The Center does not have comprehensive written policies governing drawdowns, program income application, and required reconciliations. Cause: Noncompliance with Federal cash management and program income requirements may result in questioned costs or delayed reimbursements. Effect: Late submission constitutes noncompliance with federal regulations and may delay future federal funding or result in additional oversight. Recommendation: Management should develop and adopt formal written policies detailing drawdown procedures, program income usage, and reconciliation requirements. Repeat Finding: This is not a repeat finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-011: Reporting - Insufficient Policies to Ensure Completeness and Accuracy of Reports (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: Under 2 CFR 200.328 and 200.302(b)(2), entities must maintain internal controls to ensure that financial and performance reports are accurate, complete, and supported by appropriate documentation. Condition: Reports submitted for Federal awards were not consistently reviewed for accuracy, and review procedures were not documented. Cause: The Center lacks a formal reporting policy and does not have a documented review process in place. Effect: There is an increased risk of inaccurate reporting to Federal awarding agencies, which may impact funding decisions and compliance status. Recommendation: Management should establish a formal reporting policy requiring documented supervisory reviews prior to the submission of financial and performance reports. Repeat Finding: This is not a repeat finding.