Audit 399587

Head Start Financial and Special Reporting United States Department of Health and Human Services – 93.600 Head Start Grant No(s): 06HE000754-01, 06CH011990-04, 06CH011990-03, 06HP000184-02, 06HP000184-05, 06HP000522-01 Criteria: DHHS regulations and grant awards set the criteria for DHHS Financial Reports. These reports are due quarterly, semi-annually, and annually from Head Start grantees. Financial Reports must be submitted and reviewed within a certain timeframe based upon the end of the budget period. DHHS regulations and grant awards set the criteria for DHHS Annual Special Reports (OMB No. 4040-0016). This report is due annually from Head Start grantees. Annual Special Reports must be submitted and reviewed within a certain timeframe based upon the end of the budget period. Reports should be supported by applicable accounting and performance records. Condition: Of the reports selected for testing: • One SF-425 Semi-Annual Financial Report had a submission deadline of October 30, 2024 and was submitted on June 13, 2025. • One SF-425 Annual Financial Reports had a submission deadline of July 30, 2024 and was submitted on December 27, 2024. • One SF-429 Real Property Status Report and SF-429A General Reporting report was due July 30, 2024 and was submitted on March 2, 2026. Universe/Population: The universe/population for Financial Reporting is two SF-425 Semi-Annual Financial Reports, four SF-425 Annual Financial Reports, and four SF-425 Final Reports. EA selected one of the two SF-425 Semi-Annual Financial Reports, one of the four SF-425 Annual Financial Reports, and one of the four SF-425 Final Reports for testing of reporting compliance requirements applicable to the program. The universe/population for Special Reporting is four annual SF-429 Real Property Status Reports and SF-429A General Reporting (OMB No. 4040-0016). EA selected one of the four Annual Special Reports for testing of reporting compliance requirements. Cause: Jefferson Parish lacks an established control monitoring timely submission of Financial and Special Reports. Effect: Failure to comply with the reporting requirements may result in sanctions, including: temporary withholding of cash payments, whole or partial suspension of the Federal award, suspension, debarment or limited denial of participation in Department of Health and Human Services programs pursuant to 45 CFR 75.971. Questioned Costs: None determined. Identification of a repeat finding: This is a repeat finding from the previous audit, 2023-004. Recommendation: Jefferson Parish should establish a formalized control to monitor timely submission of Financial and Special Reports. View of Responsible Officials: Management acknowledges this repeat finding and the importance of full compliance with federal reporting requirements. While progress has been made, additional monitoring is still necessary to fully remediate this issue. As part of these efforts, Jefferson Parish, has established a process to monitor the timely submission of reports in compliance with federal requirements. Management considers the corrective action to be substantially implemented. Ongoing review has been put into place to confirm continued compliance. Chief Administrative Assistant Nicole Thompson will continue to monitor the submission of timely reports in compliance with federal requirements.

Emergency Rental Assistance Program Financial and Special Reporting Department of Treasury – 21.023 Emergency Rental Assistance Program Grant No(s): 1505-0266 Criteria: Per the U.S. Department of the Treasury’s reporting guidelines for ALN 21.023, recipients are required to submit timely and complete quarterly compliance reports to ensure transparency and accountability in the use of federal funds. Condition: Of the four reports selected for testing, Jefferson Parish did not submit two quarterly reports by the grantee submission deadlines. The reports had submission deadlines of April 15, 2024 and an extended deadline of August 14, 2024 and were submitted on June 12, 2024 and August 15, 2024, respectively. Universe/Population: The universe/population for Financial Reporting is four quarterly compliance reports. EA selected all four reports for testing of reporting compliance requirements applicable to the program. Cause: Jefferson Parish lacked an established control monitoring timely submission of required reports. Effect: Late reporting may hinder the Treasury’s ability to monitor program performance and financial integrity, potentially impacting future funding decisions and compliance evaluations. Questioned Costs: None determined. Identification of a repeat finding: This is a repeat finding from the previous audit, 2023-005. Recommendation: Jefferson Parish should establish a formalized control to monitor timely submission of Financial and Special Reports. View of Responsible Officials: Management acknowledges this repeat finding and recognizes that, while prior conditions contributed to the issue, corrective actions have been implemented and significant progress has been made to resolve the finding. Since the audit finding, required compliance reports have been submitted timely. Management considers the issue resolved; however, monitoring procedures will remain in place as a precaution to ensure continued compliance. Chief Administrative Assistant Nicole Thompson and Community Development Director Stephanie Brumfield will continue to monitor the submission of timely reports in compliance with federal requirements.

Procurement and Suspension and Debarment Department of Transportation – 20.507 and 20.526 Federal Transit Cluster Grant No(s): LA-2017-025, LA-2018-016, LA-2019-008, LA-2020-010, LA-2020-020, LA-2021-011, LA-2021-023, LA-2021-032, LA-2022-023, LA-2022-024, LA-2023-022, LA-2024-012 Criteria: Title 2 CFR §200.327 requires that non Federal entities include applicable contract provisions described in Appendix II to 2 CFR Part 200 in all contracts and subcontracts funded with Federal awards. These provisions include, as applicable, clauses related to termination for cause and convenience, Equal Employment Opportunity, Davis Bacon Act (when applicable), Contract Work Hours and Safety Standards Act, Clean Air Act, debarment and suspension, Byrd Anti Lobbying Amendment, and other required federal provisions. Condition: The Parish did not include all required federal contract provisions as prescribed by 2 CFR §200.327 and Appendix II to Part 200 in 2 of 8 contracts selected for testing. Specifically, the contracts tested were missing one or more required federal provisions applicable to the nature and funding of the contracts. Universe/Population: The Parish identified 29 contracts subject to Uniform Guidance procurement requirements under the Federal Transit Cluster. From this population, 8 contracts were selected for testing. Cause: The Parish’s procurement review procedures did not include a sufficient control to ensure that all contracts funded with federal awards include the full set of applicable federal contract provisions required by Appendix II to 2 CFR Part 200 prior to execution. Effect: Failure to include required federal contract provisions increases the risk that vendors may not be contractually bound to comply with applicable federal requirements, which could result in noncompliance with Uniform Guidance procurement requirements and potential enforcement actions or repayment of federal funds. Questioned Costs: None determined. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend that the Parish strengthen procurement controls by implementing a standardized federal contract language checklist or template to ensure that all contracts funded with federal awards include the applicable provisions required by 2 CFR §200.327 and Appendix II to Part 200 prior to contract execution. View of Responsible Officials: Management acknowledges the finding and agrees that strengthening procurement controls is necessary to ensure full compliance with federal requirements. To address this issue, the Parish has implemented a standardized contract for use in federally funded procurements that incorporates all applicable requirements under 2 CFR §200.327 and Appendix II to Part 200. In this specific instance the two contracts noted were state contracts. When state contracts are utilized, the Parish will take the necessary steps to validate that such contracts include all required federal contract provisions prior to utilizing any state contracts. Guidance will also be provided to all procurement personnel involved in contracting to reinforce understanding and consistent application of federal requirements. Management expects these corrective actions to be implemented in the near term and will conduct ongoing monitoring to ensure compliance and effectiveness of the enhanced controls. Interim Finance Director Victor LaRocca, Purchasing Director Renny Simno and Assistant Accounting Director Charles “Joey” Vasquez will ensure that this is enacted immediately and that guidance is provided to procurement personnel by June of 2026.