Finding Number: 2022-002 Federal Program: CFDA 14.850 ? Public and Indian Housing Condition: A physical inventory of property and equipment was not performed in order to reconcile it with the general ledger control accounts. The property and equipment subsidiary did not include certain information that is required by the Federal Regulation, as follows: o Serial numbers o Identification and/or tag number o Percentage of federal participation on cost of units o In addition, certain acquisition dates for some of the assets needs to be revised Criteria: 2 CFR 200.313 (d) (1) establishes that property records must be maintained and should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: The property and equipment subsidiary was not reviewed in order to ascertain that all required information is properly included. Effects or potential effect: Non inclusion of all applicable information as required by the Federal Regulation. Recommendation: We recommend that management update the property and equipment report with information required by federal government and performed a physical inventory observation to reconciliate the information with general ledger accounts.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-002 Federal Program: CFDA 14.850 ? Public and Indian Housing Condition: A physical inventory of property and equipment was not performed in order to reconcile it with the general ledger control accounts. The property and equipment subsidiary did not include certain information that is required by the Federal Regulation, as follows: o Serial numbers o Identification and/or tag number o Percentage of federal participation on cost of units o In addition, certain acquisition dates for some of the assets needs to be revised Criteria: 2 CFR 200.313 (d) (1) establishes that property records must be maintained and should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: The property and equipment subsidiary was not reviewed in order to ascertain that all required information is properly included. Effects or potential effect: Non inclusion of all applicable information as required by the Federal Regulation. Recommendation: We recommend that management update the property and equipment report with information required by federal government and performed a physical inventory observation to reconciliate the information with general ledger accounts.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.
Finding Number: 2022-004 Federal Program: CFDA No. 93.600 ? Head Start (Cluster) Condition: BGCPR did not submit the required financial report (SF425) of September 2021 within the required timeline. Criteria: The program instructions (ACF-PI-HS-17-04) issued by the Department of Health and Human Services (HHS) establishes that cash transactions, expenditures, obligations, and liquidations should be reported to the Payment Management System (PMS) thru the SF-425 reports. SF-425 reports are due as required in the award terms and conditions. Reports will be due on one of the standard dates by which cash reporting is required to be submitted to PMS or at the end of a calendar quarter as determined by the Administration for Childrens and Families (ACF). The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the reporting period end date shall be the end date of the project or grant period. Cause: Lack of sufficient personnel to prepare and review the reports. BCGPR commenced the Head Start program during the year ended June 30, 2022. BGCPR was hiring the necessary personnel to cover the compliance areas. During that period, the filing of the report expired and the person to occupy the position responsible for preparing and reviewing the reports was not yet engaged. Effect or potential effect: Non-compliance with the reporting requirements. Recommendation: BGCPR should establish a calendar for submission of all required reports. Also, we recommend cross-training for key program administrative staff to avoid non-compliance in the absence of the personnel in charge.
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.