Audit 413395

Finding Type: Significant Deficiency in Internal Control Over Compliance Title and ALN of Federal Program: 93.558 – Temporary Assistance for Needy Families Criteria or Specific Requirement: B. Allowable Costs and Cost Principles - 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In addition, 2 CFR section 200.403 provides that costs charged to a Federal award must be necessary, reasonable, allocable, adequately documented, and in conformance with applicable Federal requirements and the terms and conditions of the Federal award. Condition: During the audit, it was noted that the Association was unable to provide formal support for the internal review and approval of costs relating to stipends paid that were submitted to the pass-through grantor under the major program. Cause: The Association lacks established procedures which provide formal evidence that the allowability, accuracy and completeness of stipend transactions were verified before submission. Effect or Potential Effect: Although no stipend payments were identified which exceeded the allowable amount under the subaward agreement, without adequate controls in place to ensure all charges to the federal program are properly reviewed and approved for allowability, the Association faces increased risk of noncompliance with the allowability requirement and could request funds for unallowed costs. Questioned Costs: None. Identification as a Repeat Finding: N/A — this was not reported as a finding in the prior year audit report. Context: For the stipend payments selected for testing, there was no formal support for the internal review and approval of costs submitted to the pass-through grantor under the major program. Recommendation: We recommend the Association implement a formal process for review and approval of stipend payments. This should include maintenance of a standardized stipend calculation form or comparable documentation for each payment. The documentation should identify the participant, applicable payment period, attendance and participation records and/or milestones achieved, calculation of the stipend amount, and evidence of review and approval before payment. Views of Responsible Officials: Management agrees with the finding and recommendation.

Finding Type: Noncompliance with Major Program Requirements Title and ALN of Federal Program: 93.558 – Temporary Assistance for Needy Families Criteria or Specific Requirement: E. Eligibility - 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In accordance with the Temporary Assistance for Needy Families subaward agreement, only individuals who meet the applicable eligibility criteria may receive services, benefits, or other assistance funded by the Federal award. The Association is required to maintain documentation of eligibility for program participants receiving assistance. Condition: For one of twenty-five participants selected for testing, the Association did not provide formal documentation demonstrating the participant’s eligibility for the program was determined in accordance with applicable program requirements. Cause: The Association did not have consistently established procedures to ensure that formal evidence supporting participant eligibility determinations was obtained, retained, and available for review. Effect or Potential Effect: The absence of adequate eligibility documentation increases the risk that services, benefits, or other assistance funded by the subaward could be provided to individuals who do not meet applicable eligibility requirements. Questioned Costs: None. Identification as a Repeat Finding: N/A — this was not reported as a finding in the prior year audit report. Context: Twenty-five participants were selected for testing of eligibility. For one participant, the Association did not maintain documentation supporting the participant’s eligibility determination. Recommendation: We recommend that the Association obtain, retain, and maintain documentation supporting the eligibility determination for all program participants receiving federally funded services, benefits, or other assistance. If eligibility documentation is provided or maintained through subrecipient monitoring procedures, the Association should enhance its monitoring procedures to ensure the subrecipient maintains complete enrollment forms and eligibility support for all individuals included in participant listings or reported to the pass-through entity. The Association should also perform periodic reconciliations of participant listings and Program Outcome Reports to underlying enrollment and eligibility documentation and investigate or remove from reported participant listings individuals who did not ultimately participate in the program. Views of Responsible Officials: Management agrees with the finding and recommendation.

Finding Type: Noncompliance with Major Program Requirements Title and ALN of Federal Program: 93.558 – Temporary Assistance for Needy Families Criteria or Specific Requirement: L. Reporting - Under the subaward agreement with Franklin County Department of Job and Family Services (the pass-through grantor), the Association is required to submit monthly invoices within 15 calendar days following each month-end. Additionally, submission of monthly Program Outcome Reports and a Cumulative Payroll Report supporting the invoiced costs is required to be submitted in certain instances. Condition: Four out of five monthly invoices tested were identified as being submitted to the pass-through grantor after the required 15-day deadline. In addition, the April 2025 Program Outcome Report and Cumulative Payroll Report were not submitted. Cause: The invoice delays resulted from lack of timeliness for subaward execution and reconciliation activities, completion of required supporting documentation, and certain administrative delays involving the pass-through entity. The requirement to submit the April 2025 Program Outcome Report and Cumulative Payroll Report was informally waived by the pass-through grantor. Effect or Potential Effect: Failure to submit invoices and required reports timely causes the Association to be out of compliance with grant agreements. Questioned Costs: None. Identification as a Repeat Finding: Yes – was reported as finding 2024-02. Context: For four out of five monthly invoices tested, the Association did not submit within the 15-day timeframe. The April 2025 Program Outcome Report and Cumulative Payroll Report were not submitted as this requirement was informally waived by the pass-through grantor due to timing of the subaward execution. Recommendation: The Association should establish procedures to ensure monthly invoices and required reports are prepared, reviewed, and submitted within the timeframes specified in the grant agreement. Though the pass-through grantor provided informal waivers for the instances of noncompliance, we recommend the Association obtain formal amendments for any exceptions from grant provisions to minimize the risk of uncertainty. Views of Responsible Officials and Planned Corrective Action: Management acknowledges the finding and recommendation. The Association will continue to improve its reconciliation and invoice preparation process to support timely submissions and will seek written documentation from the pass-through entity for any changes, extensions, or waivers of grant reporting requirements.