Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should be in place to ensure that participants meet the eligibility requirements for the program.
Condition: The Organization has an internal control process which requires eligibility forms to be reviewed and signed, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that the eligibility documentation was not signed by the Organization.
Effect: Ineligible individuals could be participating in the program.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 17 participants out of 85 were selected for testing. One participant had an eligibility form that was not signed by the Organization.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend management revise their internal controls to make sure the participant forms are reviewed and signed by the Organization.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Reporting
Type of Finding: Material Weakness in Internal Controls Over Compliance and Material Noncompliance
Criteria: Internal control procedures should ensure the required basis of reporting be used for all required reports.
Condition: For one report submission, the balances reported for federal share of expenditures and total administrative expenditures were reported on a cash basis rather than the required accrual basis.
Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed.
Effect: The error led to incorrect amounts being reported to the Department of Labor.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of three reports out of eight were selected for testing. One report was prepared using the incorrect basis of accounting.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the reports are submitted under the proper accrual basis and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure invoices are approved prior to payment.
Condition: The Organization has an internal control process designed to approve invoices, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that eight invoices were paid without approval documented.
Effect: Unallowable expenses could be paid by the program or outside of the period of performance.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Eight transactions did not include documentation of approval.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend the procedures related to allowable costs, activities, and period of performance be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure the correct amount is paid to employees and submitted for reimbursement.
Condition: The Organization has an internal control process designed to approve and calculate the payroll expense, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that four pay periods tested had employees that were paid the incorrect amount.
Effect: Four payroll periods were incorrectly calculated, and the wrong amount was paid to an employee and submitted for reimbursement.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of eight pay periods out of 26 total pay periods were selected for testing. Incorrect calculations were done for four pay periods selected.
Repeat Finding from Prior Years: No
Recommendation: We recommend management revise their internal controls to make sure the hours worked agree to the hours paid and submitted for reimbursement.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Award passed through the Minnesota Department of Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness in Internal Controls Over Compliance and Material Noncompliance
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that:
• Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients.
• Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the subrecipient monitoring must ensure that the subaward is used for authorized purposes.
Condition: Subawards did not contain all the required information, assistance listing numbers were not communicated at disbursement, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, and monitoring procedures were not performed.
Cause: The Organization did not have adequate internal controls to ensure risk assessment was performed or required information was communicated at the time of disbursement.
Effect: Noncompliance at the subrecipient level may occur and not be detected by the Organization.
Questioned Costs: None reported.
Context/Sampling: A non-statistical sample of three subrecipients out of a population of seven were selected for testing. Subawards were missing required information for all three subrecipients. Risk assessment was not performed for all three subrecipients.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Organization implement internal controls to ensure risk assessment is performed.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Eligibility
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should be in place to ensure that participants meet the eligibility requirements for the program.
Condition: The Organization has an internal control process which requires eligibility forms to be reviewed and signed, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that the eligibility documentation was not signed by the Organization.
Effect: Ineligible individuals could be participating in the program.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 17 participants out of 85 were selected for testing. One participant had an eligibility form that was not signed by the Organization.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend management revise their internal controls to make sure the participant forms are reviewed and signed by the Organization.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Reporting
Type of Finding: Material Weakness in Internal Controls Over Compliance and Material Noncompliance
Criteria: Internal control procedures should ensure the required basis of reporting be used for all required reports.
Condition: For one report submission, the balances reported for federal share of expenditures and total administrative expenditures were reported on a cash basis rather than the required accrual basis.
Cause: The Organization has designed internal controls over these areas; however, the controls did not operate as designed.
Effect: The error led to incorrect amounts being reported to the Department of Labor.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of three reports out of eight were selected for testing. One report was prepared using the incorrect basis of accounting.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the reports are submitted under the proper accrual basis and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure invoices are approved prior to payment.
Condition: The Organization has an internal control process designed to approve invoices, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that eight invoices were paid without approval documented.
Effect: Unallowable expenses could be paid by the program or outside of the period of performance.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Eight transactions did not include documentation of approval.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend the procedures related to allowable costs, activities, and period of performance be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing # 17.274, 2020-2023
Compliance Requirement: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure the correct amount is paid to employees and submitted for reimbursement.
Condition: The Organization has an internal control process designed to approve and calculate the payroll expense, but the controls did not operate as designed.
Cause: The controls in place did not operate as designed and failed to detect that four pay periods tested had employees that were paid the incorrect amount.
Effect: Four payroll periods were incorrectly calculated, and the wrong amount was paid to an employee and submitted for reimbursement.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of eight pay periods out of 26 total pay periods were selected for testing. Incorrect calculations were done for four pay periods selected.
Repeat Finding from Prior Years: No
Recommendation: We recommend management revise their internal controls to make sure the hours worked agree to the hours paid and submitted for reimbursement.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Award passed through the Minnesota Department of Human Services
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Material Weakness in Internal Controls Over Compliance and Material Noncompliance
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that:
• Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients.
• Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the subrecipient monitoring must ensure that the subaward is used for authorized purposes.
Condition: Subawards did not contain all the required information, assistance listing numbers were not communicated at disbursement, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, and monitoring procedures were not performed.
Cause: The Organization did not have adequate internal controls to ensure risk assessment was performed or required information was communicated at the time of disbursement.
Effect: Noncompliance at the subrecipient level may occur and not be detected by the Organization.
Questioned Costs: None reported.
Context/Sampling: A non-statistical sample of three subrecipients out of a population of seven were selected for testing. Subawards were missing required information for all three subrecipients. Risk assessment was not performed for all three subrecipients.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Organization implement internal controls to ensure risk assessment is performed.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Labor, YouthBuild
Federal Financial Assistance Listing Number # 17.274, 2020-2023
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, Awards passed through the Minnesota Department of Human Services and the City of Minneapolis
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Material Weakness in Internal Controls Over Compliance and Noncompliance
Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction.
Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors.
Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements.
Effect: A lack of established controls increases the overall risk that Organization is contracting and awarding contracts to suspended or debarred vendors or is not obtaining the best possible prices for goods or services.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing # 17.274, a nonstatistical sample of 44 transactions out of 220 total transactions were selected for testing. Required documentation related to the price comparison search was not maintained for 14 of the items selected. Required documentation related to the search for suspension and debarment was not maintained for any of the items selected.
For Federal Financial Assistance Listing # 21.027 a nonstatistical sample of seven transactions out of 21 total transactions were selected for testing. Required documentation related to the search for suspension and debarment was not maintained for two of the items selected.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement, suspension, and debarment and the procedures performed to comply with these CFR sections.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.
Department of Treasury, Coronavirus State and Local Fiscal Relief Recover Funds
Federal Financial Assistance Listing # 21.027, All Awards
Compliance Requirement: Reporting
Type of Finding: Significant Deficiency in Internal Controls Over Compliance
Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission.
Condition: For one report submitted, there was no formal documentation of the review prior to submission.
Cause: The Organization has designed internal controls over these areas; however, the controls were not formally documented and the controls failed to identify errors in reporting.
Effect: The condition may affect the Organization’s ability to support compliance with reporting requirements.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of nine reports out of 36 were selected for testing. One report did not include documentation of the review prior to submission.
Repeat Finding from Prior Years: No
Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained.
Views of Responsible Officials: Management is in agreement with this finding.