Condition: A criteria of disclosure in subrecipients? contracts was not met. The Assistance Listing Number (ALN) of funds passed through to subrecipients is not included in contracts. Criteria: Pass-through entities are required to include all information from ? 200.332(a) in contracts to subrecipients. Cause: The contract with subrecipients was not written in a way to include this required information. Effect: Subrecipients may not know that the funds received relate to a specific ALN and may as a result not include the funding from Metro Meals on Wheels in their respective Schedules of Expenditures of Federal Awards (SEFA). Recommendation: We recommend that the Executive Director and any other relevant staff review ? 200.332(a) and ensure that all requirements are met. Specifically, the expected Assistance Listing Numbers of Federal funding should be included in the subrecipient contracts. In addition, we recommend creating a year-end summary report for each subrecipient which should indicate the total funding given through each ALN (if more than one) or other funding sources.
Condition: Metro Meals on Wheels does not have policies in place to fulfill or record the fulfillment of the criteria. Specifically, Metro Meals on Wheels does not document risks of the subrecipient, document monitoring procedures to fulfill all monitoring requirements in the criteria, issue remedial management decisions and follow-up on findings, or ensure that subrecipients receive single audits if required. Criteria: Metro Meals on Wheels is required to make risk assessments and monitor subrecipients according to ? 200.332(b)-(h). These requirements include evaluating subrecipient risks of not fulfilling Aging Program requirements, monitoring actual activity of the subrecipient, issuing management findings on deficiencies in completing program requirements, following up on deficiencies, ensuring that subrecipients receive a single audit if required and acting on subrecipient findings from single audits. Cause: Procedures to fulfill the criteria have not been developed by Metro Meals on Wheels? management. Effect: Subrecipients may need additional oversight action. Recommendation: Our recommendations include a few steps. First, we recommend that management develop documentation regarding how risks of subrecipients are evaluated yearly. This documentation should include considerations of subrecipient weaknesses and any follow-up actions taken. It should also document resolution processes and whether resolution was made. (Not all subrecipients will need remedial action. This conclusion should be documented as well.) Second, we recommend that management develop paperwork to properly monitor subrecipients and follow-up on deficiencies according to ? 200.332. These processes have started in 2022. Site visit documentation can be modified to include useful documentation for these purposes. In addition, management can consider the MMOW funder?s site visit documentation in monitoring procedures. If the funder?s monitoring of Metro Meals on Wheels? subrecipients is used by management, the funder?s documentation should be reviewed and stored as support by management. Third, we recommend recording any remedial action taken during the year related to subrecipient errors. Fourth, we recommend developing a year-end report that includes a reminder for subrecipients to perform a single audit, if required, and notify Metro Meals on Wheels of the audit results as it pertains to the passed through funding.
Condition: The Program Manager fills out required monthly and quarterly reports and sends them to MMOW?s funder. In order to control that these reports are correct, the Program Manager sends a report to accounting that contains the monthly amounts requested from MMOW?s funder. We found in the course of the audit that this report did not match the monthly or quarterly reports sent to MMOW?s funder. Criteria: Metro Meals on Wheels is required to have functioning internal controls over the reporting compliance requirement. Controls must be designed to adequately reduce fraud and error and also must function as designed. Cause: No individual was checking that these reports matched the reports sent to MMOW?s funder. Effect: The effect is that money received from MMOW?s funder was different than what was expected by accounting and the Executive Director. The control was not strong enough to catch errors in reporting. Recommendation: We recommend that the Executive Director review the report that the Program Manager sends to himself and accounting and compare it with the report the Program Manager sends to MMOW?s funder. We recommend that this report is reviewed and signed-off on and kept in documented files. Any inconsistencies should be noted by the Executive Director, reviewed, and reconciled. If the difference can be reconciled it should be noted.
Condition: Federal expenses disbursed to subrecipients were reported in the period expensed under Generally Accepted Accounting Principles instead of the date when the cash was disbursed. Criteria: Metro Meals on Wheels is responsible to report federal expenditures on the Schedule of Expenditures of Federal Awards according to 2 CFR ? 200.510. In addition, this section refers to requirements in 2 CRF ? 200.502. It requires that MMOW report expenditures in specific ways, including reporting disbursements to subrecipients when the cash is disbursed. Cause: The requirement referenced in the criteria is a departure from GAAP which Metro Meals on Wheels did not recognize at the time of preparing the SEFA. Effect: The original SEFA submitted to the auditors contained an inaccurate amount of awards. Recommendation: We recommend that Metro Meals on Wheels track when Federal funds are disbursed to subrecipients and report these expenditures on the SEFA in the period of disbursement.
Condition: A criteria of disclosure in subrecipients? contracts was not met. The Assistance Listing Number (ALN) of funds passed through to subrecipients is not included in contracts. Criteria: Pass-through entities are required to include all information from ? 200.332(a) in contracts to subrecipients. Cause: The contract with subrecipients was not written in a way to include this required information. Effect: Subrecipients may not know that the funds received relate to a specific ALN and may as a result not include the funding from Metro Meals on Wheels in their respective Schedules of Expenditures of Federal Awards (SEFA). Recommendation: We recommend that the Executive Director and any other relevant staff review ? 200.332(a) and ensure that all requirements are met. Specifically, the expected Assistance Listing Numbers of Federal funding should be included in the subrecipient contracts. In addition, we recommend creating a year-end summary report for each subrecipient which should indicate the total funding given through each ALN (if more than one) or other funding sources.
Condition: Metro Meals on Wheels does not have policies in place to fulfill or record the fulfillment of the criteria. Specifically, Metro Meals on Wheels does not document risks of the subrecipient, document monitoring procedures to fulfill all monitoring requirements in the criteria, issue remedial management decisions and follow-up on findings, or ensure that subrecipients receive single audits if required. Criteria: Metro Meals on Wheels is required to make risk assessments and monitor subrecipients according to ? 200.332(b)-(h). These requirements include evaluating subrecipient risks of not fulfilling Aging Program requirements, monitoring actual activity of the subrecipient, issuing management findings on deficiencies in completing program requirements, following up on deficiencies, ensuring that subrecipients receive a single audit if required and acting on subrecipient findings from single audits. Cause: Procedures to fulfill the criteria have not been developed by Metro Meals on Wheels? management. Effect: Subrecipients may need additional oversight action. Recommendation: Our recommendations include a few steps. First, we recommend that management develop documentation regarding how risks of subrecipients are evaluated yearly. This documentation should include considerations of subrecipient weaknesses and any follow-up actions taken. It should also document resolution processes and whether resolution was made. (Not all subrecipients will need remedial action. This conclusion should be documented as well.) Second, we recommend that management develop paperwork to properly monitor subrecipients and follow-up on deficiencies according to ? 200.332. These processes have started in 2022. Site visit documentation can be modified to include useful documentation for these purposes. In addition, management can consider the MMOW funder?s site visit documentation in monitoring procedures. If the funder?s monitoring of Metro Meals on Wheels? subrecipients is used by management, the funder?s documentation should be reviewed and stored as support by management. Third, we recommend recording any remedial action taken during the year related to subrecipient errors. Fourth, we recommend developing a year-end report that includes a reminder for subrecipients to perform a single audit, if required, and notify Metro Meals on Wheels of the audit results as it pertains to the passed through funding.
Condition: The Program Manager fills out required monthly and quarterly reports and sends them to MMOW?s funder. In order to control that these reports are correct, the Program Manager sends a report to accounting that contains the monthly amounts requested from MMOW?s funder. We found in the course of the audit that this report did not match the monthly or quarterly reports sent to MMOW?s funder. Criteria: Metro Meals on Wheels is required to have functioning internal controls over the reporting compliance requirement. Controls must be designed to adequately reduce fraud and error and also must function as designed. Cause: No individual was checking that these reports matched the reports sent to MMOW?s funder. Effect: The effect is that money received from MMOW?s funder was different than what was expected by accounting and the Executive Director. The control was not strong enough to catch errors in reporting. Recommendation: We recommend that the Executive Director review the report that the Program Manager sends to himself and accounting and compare it with the report the Program Manager sends to MMOW?s funder. We recommend that this report is reviewed and signed-off on and kept in documented files. Any inconsistencies should be noted by the Executive Director, reviewed, and reconciled. If the difference can be reconciled it should be noted.
Condition: Federal expenses disbursed to subrecipients were reported in the period expensed under Generally Accepted Accounting Principles instead of the date when the cash was disbursed. Criteria: Metro Meals on Wheels is responsible to report federal expenditures on the Schedule of Expenditures of Federal Awards according to 2 CFR ? 200.510. In addition, this section refers to requirements in 2 CRF ? 200.502. It requires that MMOW report expenditures in specific ways, including reporting disbursements to subrecipients when the cash is disbursed. Cause: The requirement referenced in the criteria is a departure from GAAP which Metro Meals on Wheels did not recognize at the time of preparing the SEFA. Effect: The original SEFA submitted to the auditors contained an inaccurate amount of awards. Recommendation: We recommend that Metro Meals on Wheels track when Federal funds are disbursed to subrecipients and report these expenditures on the SEFA in the period of disbursement.