Audit 386041

Finding 2024-003 – Allowable Costs Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Pass-through: City of Columbus Award Number: 2576-2021 Award Year: 10/18/2021 – 12/31/2026 Type of Finding: Material Weakness and Noncompliance Criteria: Per 2 CFR 200.403, Costs charged to federal awards must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. In addition, they must not be included as a cost or used to meet cost-sharing requirements of any other federally-financed program in either the current or a prior period. Condition: The controls in place were not sufficient to ensure costs submitted for reimbursement were complete and accurate. Context: The Association included the same payroll costs to two different invoices (requests for cost reimbursement) for the ARPA Relocation subgrant passed through the City of Columbus. These two invoices were submitted and recorded as revenue in 2024 and consist of costs incurred in 2023 and 2024. The payroll costs submitted in the first invoice totaled $107,668 while the second invoice contained payroll costs of $119,120. The difference between those amounts represents additional payroll costs for one employee for pay dates between May and June 2024. Cause: The underlying cause was due to an oversight of the disbursement journal reviewer. Effect: The Association submitted a duplicate invoice for payroll expenditures that were already reimbursed. Questioned costs: $107,668 Identification of how questioned costs were computed: See explanation provided in the Context. Repeat finding: No. Recommendation: The Association should review its policies and procedures to ensure the same costs are not duplicated among different invoices submitted for cost reimbursement. Views of responsible officials: See Corrective Action Plan

Finding 2024-004 – Suspension/Debarment Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Pass-through: City of Columbus and Community Shelter Board Award Number: 2920-2021 and YMCA-24-CSB Award Year: Various Type of Finding: Significant Deficiency and Noncompliance Criteria: Per 2 CFR 200.414, "Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards." Per 2 CFR 180 Subpart C, section 300, recommendations to verify that the person or company you intend to do business with is not excluded or disqualified include: (a) Checking SAM.gov Exclusions, (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person. Condition: The controls in place were not sufficient to ensure vendors the Association transacted with were not debarred, suspended, or otherwise excluded from participating in Federal awards. Context: Out of three vendors selected for testing, the Association did not verify whether they were suspended or debarred from entering into federally covered transactions for any of them. Cause: The Association indicated that they were not familiar with this compliance requirement for this funding. Effect: The Association did not identify the need to verify vendors and therefore did not have any support that they verified vendors for this program. Questioned costs: None. Identification of how questioned costs were computed: Not applicable. Repeat finding: No. Recommendation: The Association should put processes in place that ensures vendors are not suspended or debarred from entering into transactions involving Federal awards and retain documentation of the verification. Views of responsible officials: See Corrective Action Plan.

Finding 2024-005 – Period of Performance Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds AL Number: 21.027 Pass-through: Community Shelter Board Award Number: YMCA-24-CSB and YMCA-25-CSB Award Year: 7/1/2023 – 6/30/2024 and 7/1/2024 – 6/30/2025 Type of Finding: Material Weakness and Noncompliance Criteria: 2 CFR 200.403(h): Administrative closeout costs may be incurred until the due date of the final report(s). If incurred, these costs must be liquidated prior to the due date of the final report(s) and charged to the final budget period of the award unless otherwise specified by the Federal agency. All other costs must be incurred during the approved budget period. 2 CFR 200.302: The recipient's and subrecipient's financial management system must provide for the following: Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition: The Association was unable to verify whether costs recorded in the financial accounting system were included in invoices submitted for cost reimbursement. As such, auditors could not verify whether these costs were included in the appropriate period of performance. Context: Out of a sample of 40 transactions tested for compliance with period of performance requirements, 27 of them could not be traced to a reimbursement invoice. Most of these transactions were transfers of payroll costs from one program to another. Cause: The Association did not have a strong process to track program expenses with the financial accounting system and did not effectively reconcile expenditures between the general ledger and the Schedule of Expenditures of Federal Awards. In addition, the Association did not maintain support for expenditures charged to federal grants to be able to support whether they were within the allowable period of performance. Effect: The Association could not provide evidence of whether the transactions tested were within the period of performance. Questioned costs: $602,142 Identification of how questioned costs were computed: Known questioned costs were computed by summing the dollar amount of selections that were identified as errors which totaled $6,829. An error rate was calculated by taking the number of errors divided by the total sample size as described in the Context section. This error rate was then applied to the untested population to calculate projected questioned costs of $595,313. Repeat finding: Not applicable. Recommendation: The Association should review its policies and procedures to ensure costs recorded in the financial accounting system are able to be reconciled to invoices submitted for cost reimbursement as well as the Schedule of Expenditures of Federal Awards. Views of responsible officials: See Corrective Action Plan.