Audit 407388

2022-002 - Reporting Program: Congressional Appropriations Program (ALN 99.U19) Federal Agency: United States Department of Treasury Criteria: Quarterly reports are required to be submitted to the Online Reporting System (ORS) in accordance with contract specifications beginning in the first quarter of 2022 through June of 2023. Per 2 CFR section 200.303(a), a non-Federal entity must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Supporting documentation was not available to substantiate certain key line items included in the quarterly reports. In addition, we did not observe evidence of supervisory review and approval prior to submission. Cause: The Organization did not have adequate controls to ensure supporting documentation was retained for all reports, including documentation reports were properly reviewed and approved prior to submission. Effect: The Organization was not in compliance with the programs reporting requirements and lacked internal controls over the review and approval of reports. Questioned Costs: Undetermined Context: We tested 4 of 4 quarterly reports submitted during the audit period, totaling reported federal expenditures of $489,764. Repeat Finding: No Recommendation: We recommend that management review their policies and procedures to ensure that all quarterly reports and the supporting documentation used to prepare the reports are retained for audit purposes. We further recommend that all reports be reviewed and approved by someone other than the preparer prior to submission. Views of Responsible Officials: See Corrective Action Plan.

2022-003 – Suspension and debarment Program: Congressional Appropriations Program (ALN 99.U19) Federal Agency: United States Department of Treasury Criteria: In accordance with 2 CFR 180.300 non-Federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in Federal programs. The Organization is required to maintain procedures and controls to verify the eligibility of vendors and subrecipients subject to these requirements prior to entering into covered transactions. Condition: The Organization was not able to provide supporting documentation that the Organization verified subrecipients were not suspended or debarred prior to entering into transactions. Cause: The Organization did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Effect: The auditor noted no instances of noncompliance with the provisions of suspension and debarment; however, we were not able to verify that the Organization followed their internal control procedures to ensure the subrecipient was not suspended or debarred prior to entering the transaction. Questioned Costs: None Context: The Organization could not provide documentation demonstrating that suspension and debarment verification procedures were performed and documented for 2 of 6 subrecipients subject to the requirements of 2 CFR 180.300. Samples were selected using nonstatistical sampling. Repeat Finding: No Recommendation: We recommend the Organization implement procedures to ensure that documentation of the verification process for suspension and debarment is maintained to support the Organization's internal control over compliance. Views of Responsible Officials: See Corrective Action Plan.

2022-004 – Subrecipient Monitoring Program: Congressional Appropriations Program (ALN 99.U19) Federal Agency: United States Department of Treasury Criteria: 2 CFR part 200.332 require that all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award and includes the following information at the time of the sub-award and if any of these data elements change, include the changes in subsequent sub-award modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and sub-award. Required information includes (1) Federal Award Identification (i) subrecipient name; (ii) subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date of award to the recipient by the Federal agency (v) sub-award period of performance state and end date; (vi) amount of Federal funds obligated by this action by the pass-through entity to the subrecipient; (vii) total amount of federal funds obligated to the subrecipient by the pass-through entity including the current obligations; (viii) total amount of the federal award committed to the subrecipient by the pass-through entity; (ix) federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (x) name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xi) ALN number and name; (xii) identification of whether the award is R&D; and (xiii) indirect cost rate for the Federal Award. Condition: The Organization did not include all required information in the subaward agreement per 2 CFR part 200.332. Cause: The Organization does not have effective controls in place to ensure sub-awards contain all required information. Effect: Subgrantees may not have the information needed to identify a subaward as federal funding to ensure compliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and specific federal program requirements. Questioned Costs: None Context: The Organization issued 20 subawards during the year. Of the 4 subaward agreements selected for testing through non-statistical sampling, all 4 were missing one or more elements required to be included in subaward agreements under 2 CFR 200.332. Repeat Finding: No Recommendation: We recommend that the Organization review and enhance their current procedures to ensure all requirements found in 2 CFR section 200.332 are present in subaward agreements. Views of Responsible Officials: See Corrective Action Plan.

2022-005 – Subrecipient Monitoring Program: Congressional Appropriations Program (ALN 99.U19) Federal Agency: United States Department of Treasury Criteria: In accordance with 2 CFR part 200.332(e) pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In accordance with 2 CFR part 200.303(a), nonfederal entities receiving federal awards must establish, document, and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring on-site review procedures are performed in a timely manner, are designed to monitor fiscal controls, and are performed to ensure compliance with program regulations. Condition: The Organization enters into agreements with subrecipients and, as part of its subrecipient monitoring procedures, requires subrecipients to submit quarterly vouchers and audited financial statements. However, the Organization did not consistently maintain evidence that audited financial statements were obtained and reviewed or that quarterly vouchers were reviewed and reconciled to amounts reported by subrecipients in the Online Reporting System. Cause: Management did not implement adequate procedures to ensure that required subrecipient monitoring activities were performed and documented in accordance with the Organization’s policies and 2 CFR 200.332(e). Effect: Failure to conduct monitoring of subrecipients results in noncompliance with 2 CFR part 200.332(e) and a failure of the internal control environment surrounding subrecipient monitoring. In addition, failure to conduct monitoring of subrecipients could result in disallowed costs. Questioned Costs: Undetermined Context: The Organization issued 20 subawards during the year. Of the 4 subrecipients selected for testing through nonstatistical sampling, 1 subrecipient lacked evidence that audited financial statements were obtained and reviewed. In addition, for 4 out of 4 subrecipients tested, the Organization did not maintain evidence that quarterly vouchers were reviewed and reconciled to amounts reported by the subrecipients in the Online Reporting System. Repeat Finding: No Recommendation: We recommend that the Organization review and enhance their current procedures to ensure monitoring procedures are documented and maintained. Views of Responsible Officials: See Corrective Action Plan.