Audit 42830

2022 ? 001 Federal Agency: Department of Health and Human Services Federal Program Name: Maternal, Infant, and Early Childhood Home Visiting Grant Program Listing Number: 93.870 Federal Award Identification Number and Year: EVVMPGHM8QB3 Pass-Through Agency: Connecticut Office of Early Childhood Pass-Through Number: 12060-OEC64860-22683 Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: There was no documentation maintained to show that verification was performed before EdAdvance entered into a transaction with subrecipients. Questioned costs: None Context: We reviewed 2 out of the 4 subrecipients of the grant. Per discussion with management, they verbally confirmed with subrecipients that they are not suspended or debarred and subsequently confirmed that they are not listed under the Excluded Parties List System. However, there was no documentation showing that the verification was performed before EdAdvance entered into a transaction with subrecipients. Cause: Improper monitoring controls of review procedures and documentation policies Effect: There is no evidence that the verification was performed before entering into a transaction with subrecipients. Repeat Finding: No

Recommendation: We recommend that management retain documentation of verification performed over subrecipients. Views of Responsible Officials: There is no disagreement with the audit finding. 2022 ? 002 Federal Agency: Department of Health and Human Services Federal Program Name: Maternal, Infant, and Early Childhood Home Visiting Grant Program Listing Number: 93.870 Federal Award Identification Number and Year: EVVMPGHM8QB3 Pass-Through Agency: Connecticut Office of Early Childhood Pass-Through Number: 12060-OEC64860-22683 Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The HHS Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR Part 75) requires pass-through entities: (1) to evaluate each subrecipient?s risk of noncompliance in order to determine the appropriate monitoring level; (2) monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable federal statutes and regulations and terms of the subaward; and (3) verify that subrecipients are audited as required under this guidance. Specifically, the grantee must conduct monitoring activities in accordance with sections 75.351 through 75.353 of Subpart D of 45 CFR Part 75. Grantees must ensure that all requirements imposed by the federal government are passed down to subrecipients so that the HHS award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. Condition: The following award information was not communicated to the subrecipients: assistance listing title and number; award name and number; and name of federal awarding agency. Questioned costs: None Context: We reviewed 2 out of the 4 subrecipients of the grant. We obtained the subaward agreement and noted that the following award information was not included: assistance listing title and number; award name and number; and name of federal awarding agency. Cause: Improper monitoring controls of subrecipient monitoring procedures Effect: The following award information was not communicated to the subrecipients: assistance listing title and number; award name and number; and name of federal awarding agency. Repeat Finding: No

2022 ? 001 Federal Agency: Department of Health and Human Services Federal Program Name: Maternal, Infant, and Early Childhood Home Visiting Grant Program Listing Number: 93.870 Federal Award Identification Number and Year: EVVMPGHM8QB3 Pass-Through Agency: Connecticut Office of Early Childhood Pass-Through Number: 12060-OEC64860-22683 Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: There was no documentation maintained to show that verification was performed before EdAdvance entered into a transaction with subrecipients. Questioned costs: None Context: We reviewed 2 out of the 4 subrecipients of the grant. Per discussion with management, they verbally confirmed with subrecipients that they are not suspended or debarred and subsequently confirmed that they are not listed under the Excluded Parties List System. However, there was no documentation showing that the verification was performed before EdAdvance entered into a transaction with subrecipients. Cause: Improper monitoring controls of review procedures and documentation policies Effect: There is no evidence that the verification was performed before entering into a transaction with subrecipients. Repeat Finding: No

Recommendation: We recommend that management retain documentation of verification performed over subrecipients. Views of Responsible Officials: There is no disagreement with the audit finding. 2022 ? 002 Federal Agency: Department of Health and Human Services Federal Program Name: Maternal, Infant, and Early Childhood Home Visiting Grant Program Listing Number: 93.870 Federal Award Identification Number and Year: EVVMPGHM8QB3 Pass-Through Agency: Connecticut Office of Early Childhood Pass-Through Number: 12060-OEC64860-22683 Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The HHS Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR Part 75) requires pass-through entities: (1) to evaluate each subrecipient?s risk of noncompliance in order to determine the appropriate monitoring level; (2) monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable federal statutes and regulations and terms of the subaward; and (3) verify that subrecipients are audited as required under this guidance. Specifically, the grantee must conduct monitoring activities in accordance with sections 75.351 through 75.353 of Subpart D of 45 CFR Part 75. Grantees must ensure that all requirements imposed by the federal government are passed down to subrecipients so that the HHS award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. Condition: The following award information was not communicated to the subrecipients: assistance listing title and number; award name and number; and name of federal awarding agency. Questioned costs: None Context: We reviewed 2 out of the 4 subrecipients of the grant. We obtained the subaward agreement and noted that the following award information was not included: assistance listing title and number; award name and number; and name of federal awarding agency. Cause: Improper monitoring controls of subrecipient monitoring procedures Effect: The following award information was not communicated to the subrecipients: assistance listing title and number; award name and number; and name of federal awarding agency. Repeat Finding: No