MW 2022-004 Review of Reimbursement Requests and Expenses Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reimbursement requests and monthly expense reports should be subject to independent review to verify the completeness and accuracy of the request and attached support. Condition: Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Individual payroll and non-payroll expenses were not consistently subject to review for allowability. Cause: Staff mistakenly omitted required support or input incorrect amounts. Staff mistakenly submitted a disallowed expense within a reimbursement request discovered by the pass through entity. Effect: A reimbursement request included errors and unsupported expenses. The grantor identified the errors and omissions and required the reimbursement request be resubmitted with the corrections and required support. The Organization did not have procedures to document the review of individual payroll and non-payroll expenses for allowability. Questioned Costs: None Perspective: The Executive Director has implemented procedures to organize reimbursement request and monthly expense documentation to make it easier to ensure the completeness and accuracy of the submissions to the grantor. However, these documents are often very long, and human error may not be completely avoidable through the current method of documentation. Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. We have already implemented the recommended process for the review of reimbursement requests and monthly expense submissions. These are documented to ensure the completeness and accuracy of the submission. We also implemented the documentation of the review of individual payroll and non-payroll expense allowability. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit.
SD 2022-005 Support for Matching Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 24 CFR 576.201 specifies the recipient must make matching contributions to supplement the recipient's ESG program in an amount that equals the recipient's fiscal year grant for ESG. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The sources of matching funds, required by awards, should be documented and retained. Condition: Subrecipient requests for reimbursement did not include detail support for matching funds. Cause: At the outset of the award, subrecipients specify the types of match (cash, in-kind, service, use of facilities, etc.) they will provide for the award and they provide the amount of the match for each month on the monthly invoice/request for reimbursement. However, no support is provided for the type, quantity, or value of match during the month. Effect: The required matching funds may not be obtained for the award. Questioned Costs: None Perspective: Support for matching was not obtained for any subrecipients. Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The FY 20-21 Audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We require match documentation to be provided upfront during the competitive RFP. We detailed in each sub-recipient contract the Match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of Match monthly. These sub-recipient contracts went into effect July 1, 2022 making the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.
SD 2022-006 Subrecipient Procurement Policy Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR Part 180 prohibits award recipients from entering into covered transactions with vendors who are suspended or debarred. Further, 2 CFR 200.320 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Policies and procedures at subrecipient organizations should ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Condition: Subrecipients are required to have procurement policies which ensure competitive procurement and use vendors who are not suspended or debarred for grant-funded expenditures. Cause: The Organization has not developed a process to monitor this requirement for subrecipients. Effect: The Organization may reimburse subrecipients for transactions which did not comply with competitive procurement requirements or were made with suspended or debarred vendors. Questioned Costs: None Perspective: The Organization has competitive procurement procedures and verifies vendors are in good-standing for their grant-funded expenses. Procurement policies at subrecipients have not been required to be provided or evaluated. Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We addressed the procurement policies with our existing subcontractors during their fiscal year 21-22 Monitoring visits in May, 2022. We added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. All new sub-recipient contracts that went into effect July 1, 2022 made the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.
MW 2022-004 Review of Reimbursement Requests and Expenses Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reimbursement requests and monthly expense reports should be subject to independent review to verify the completeness and accuracy of the request and attached support. Condition: Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Individual payroll and non-payroll expenses were not consistently subject to review for allowability. Cause: Staff mistakenly omitted required support or input incorrect amounts. Staff mistakenly submitted a disallowed expense within a reimbursement request discovered by the pass through entity. Effect: A reimbursement request included errors and unsupported expenses. The grantor identified the errors and omissions and required the reimbursement request be resubmitted with the corrections and required support. The Organization did not have procedures to document the review of individual payroll and non-payroll expenses for allowability. Questioned Costs: None Perspective: The Executive Director has implemented procedures to organize reimbursement request and monthly expense documentation to make it easier to ensure the completeness and accuracy of the submissions to the grantor. However, these documents are often very long, and human error may not be completely avoidable through the current method of documentation. Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. We have already implemented the recommended process for the review of reimbursement requests and monthly expense submissions. These are documented to ensure the completeness and accuracy of the submission. We also implemented the documentation of the review of individual payroll and non-payroll expense allowability. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit.
SD 2022-005 Support for Matching Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 24 CFR 576.201 specifies the recipient must make matching contributions to supplement the recipient's ESG program in an amount that equals the recipient's fiscal year grant for ESG. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The sources of matching funds, required by awards, should be documented and retained. Condition: Subrecipient requests for reimbursement did not include detail support for matching funds. Cause: At the outset of the award, subrecipients specify the types of match (cash, in-kind, service, use of facilities, etc.) they will provide for the award and they provide the amount of the match for each month on the monthly invoice/request for reimbursement. However, no support is provided for the type, quantity, or value of match during the month. Effect: The required matching funds may not be obtained for the award. Questioned Costs: None Perspective: Support for matching was not obtained for any subrecipients. Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The FY 20-21 Audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We require match documentation to be provided upfront during the competitive RFP. We detailed in each sub-recipient contract the Match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of Match monthly. These sub-recipient contracts went into effect July 1, 2022 making the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.
SD 2022-006 Subrecipient Procurement Policy Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR Part 180 prohibits award recipients from entering into covered transactions with vendors who are suspended or debarred. Further, 2 CFR 200.320 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Policies and procedures at subrecipient organizations should ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Condition: Subrecipients are required to have procurement policies which ensure competitive procurement and use vendors who are not suspended or debarred for grant-funded expenditures. Cause: The Organization has not developed a process to monitor this requirement for subrecipients. Effect: The Organization may reimburse subrecipients for transactions which did not comply with competitive procurement requirements or were made with suspended or debarred vendors. Questioned Costs: None Perspective: The Organization has competitive procurement procedures and verifies vendors are in good-standing for their grant-funded expenses. Procurement policies at subrecipients have not been required to be provided or evaluated. Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We addressed the procurement policies with our existing subcontractors during their fiscal year 21-22 Monitoring visits in May, 2022. We added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. All new sub-recipient contracts that went into effect July 1, 2022 made the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.