Audit 574

Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Federal Agency: HHS AL Numbers and Titles: 93.592 - Family Violence Prevention and Services/Discretionary Federal Award Number: 90EV0531 Questioned Costs: None Repeat Finding: No Criteria: 2 CFR §200.303 – Internal Controls of the Uniform Guidance states that the non‐federal entity must: (a) Establish 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 be in compliance with 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). 2 CFR §170 requires non‐Federal entities making first‐tier subawards of Federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109‐282), as amended by section 6202 of Public Law 110‐252. Compliance with FFATA requires prime recipients to report subaward and executive compensation data about the sub‐awards to the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward obligation was made, if the subaward amount is greater than or equal to $30,000. Condition: We reviewed all subawards made by the grantee during the audit period and found that 4 of them, totaling $224,000, were not reported to the FSRS. Cause: Caminar Latino did not have adequate policies and procedures to ensure timely and accurate reporting of subaward data to the FSRS. Effect: The grantee did not comply with the FFATA reporting requirement, which could result in a lack of transparency and accountability for the use of Federal funds. Recommendation: We recommend Caminar Latino develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials Corrective Actions: Caminar Latino, Inc. agrees with this finding. Please refer to the Corrective Action Plan.

Compliance Requirement: Allowable Costs/Cost Principles (Indirect Costs), Cash Management Internal Control Impact: Significant Deficiency Federal Agency: HHS AL Numbers and Titles: 93.592 - Family Violence Prevention and Services/Discretionary Federal Award Number: 90EV0474, 90EV0501, 90EV0531 Questioned Costs: None Repeat Finding: Yes, 2021-002 and 2021-003 Criteria: As a recipient of federal awards, Caminar Latino is required to establish and maintain effective internal controls over federal awards that provide reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award pursuant to Title 2. U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.303 – Internal Controls. Additionally, Caminar Latino’s corrective action plans related to the fiscal year 2021 finding 2021-002 and 2021-003 state that the Caminar Latino will implement segregation of duties over the preparation and review of indirect cost calculations and drawdowns. Condition: Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determine the reports were materially accurate; however, no evidence of a formal supervisory review and approval of the reconciliation was maintained on-file in these three instances. Cause: Due to the timing of the prior year audit results, Caminar Latino did not implement its corrective action plan and maintain documentation of the review and approval of the indirect costs calculations and drawdowns submitted until the end of the fiscal year under review. Effect: A lack of independent review of the drawdowns could result in a reasonable possibility that Caminar Latino would not detect errors in the normal course of performing duties and correct them in a timely manner. Recommendation: Caminar Latino should establish a system to document and verify the review and approval of each federal drawdown by someone independent of the preparation of the drawdown request. Views of Responsible Officials and Corrective Actions: Caminar Latino agrees with this finding. Please refer to the Corrective Action Plan.

Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Federal Agency: HHS AL Numbers and Titles: 93.592 - Family Violence Prevention and Services/Discretionary Federal Award Number: 90EV0531 Questioned Costs: None Repeat Finding: No Criteria: 2 CFR §200.303 – Internal Controls of the Uniform Guidance states that the non‐federal entity must: (a) Establish 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 be in compliance with 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). 2 CFR §170 requires non‐Federal entities making first‐tier subawards of Federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109‐282), as amended by section 6202 of Public Law 110‐252. Compliance with FFATA requires prime recipients to report subaward and executive compensation data about the sub‐awards to the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward obligation was made, if the subaward amount is greater than or equal to $30,000. Condition: We reviewed all subawards made by the grantee during the audit period and found that 4 of them, totaling $224,000, were not reported to the FSRS. Cause: Caminar Latino did not have adequate policies and procedures to ensure timely and accurate reporting of subaward data to the FSRS. Effect: The grantee did not comply with the FFATA reporting requirement, which could result in a lack of transparency and accountability for the use of Federal funds. Recommendation: We recommend Caminar Latino develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials Corrective Actions: Caminar Latino, Inc. agrees with this finding. Please refer to the Corrective Action Plan.

Compliance Requirement: Allowable Costs/Cost Principles (Indirect Costs), Cash Management Internal Control Impact: Significant Deficiency Federal Agency: HHS AL Numbers and Titles: 93.592 - Family Violence Prevention and Services/Discretionary Federal Award Number: 90EV0474, 90EV0501, 90EV0531 Questioned Costs: None Repeat Finding: Yes, 2021-002 and 2021-003 Criteria: As a recipient of federal awards, Caminar Latino is required to establish and maintain effective internal controls over federal awards that provide reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award pursuant to Title 2. U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.303 – Internal Controls. Additionally, Caminar Latino’s corrective action plans related to the fiscal year 2021 finding 2021-002 and 2021-003 state that the Caminar Latino will implement segregation of duties over the preparation and review of indirect cost calculations and drawdowns. Condition: Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determine the reports were materially accurate; however, no evidence of a formal supervisory review and approval of the reconciliation was maintained on-file in these three instances. Cause: Due to the timing of the prior year audit results, Caminar Latino did not implement its corrective action plan and maintain documentation of the review and approval of the indirect costs calculations and drawdowns submitted until the end of the fiscal year under review. Effect: A lack of independent review of the drawdowns could result in a reasonable possibility that Caminar Latino would not detect errors in the normal course of performing duties and correct them in a timely manner. Recommendation: Caminar Latino should establish a system to document and verify the review and approval of each federal drawdown by someone independent of the preparation of the drawdown request. Views of Responsible Officials and Corrective Actions: Caminar Latino agrees with this finding. Please refer to the Corrective Action Plan.