Corrective Action Plans

Finding 485445 (2022-006)

Material Weakness 2022

CA

Subrecipient Monitoring § 200.1 § 200.303 § 200.331 § 200.332 § 200.414

2022-006 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring T...

2022-006 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023

View Audit 318179

Finding 485381 (2022-003)

Material Weakness 2022

So Consortium

OH

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding Reference Number: 2022-003 Name of Responsible Person: Steve Sturgill, Executive Director Reporting Views of Responsible Officials: We concur that the Organization does not consistently review grant agreement required reports prior to their submission and properly store record of the report ...

Finding Reference Number: 2022-003 Name of Responsible Person: Steve Sturgill, Executive Director Reporting Views of Responsible Officials: We concur that the Organization does not consistently review grant agreement required reports prior to their submission and properly store record of the report summitted, supporting documentation and the date the report was submitted. Concur or Do Not Concur with this Finding: Concur Agree or Disagree with Auditor Recommendations: Agree Completion Date of Proposed Completion Date: October 31, 2024 Actions Taken or Planned on this Finding: We acknowledge the material weaknesses identified in the financial statements and related to federal awards as well as the qualified audit opinion issued by Tidwell regarding our compliance for the major programs for the year ended October 31, 2022. The material weaknesses identified and the qualified audit opinion on compliance for the major programs indicates that while the financial statements -provide a true and fair view of our financial position, there are specific areas that require attention and improvement. We appreciate the thoroughness of the audit process conducted by Tidwell Group, LLC, which has provided valuable insights into our financial reporting practices. In response to the material weaknesses identified and the qualified audit opinion regarding compliance for major programs, we are committed to addressing the concerns raised by the auditors. Our immediate steps include: 1) Reviewing Accounting Policies: We will review and possibly revise our accounting policies to ensure they are aligned with industry standards and regulatory requirements. 2) Enhancing Internal Controls: We recognize the importance of robust internal controls. Therefore, we will strengthen our internal control mechanisms to mitigate risks and ensure the accuracy of financial reporting. 3) Improving Financial Reporting Practices: We will enhance our financial reporting practices to provide more transparent and comprehensive disclosures. 4) Engaging with Stakeholders: We will communicate openly with our stakeholders, including board members, regulators, and creditors, to address any concerns arising from the material weaknesses identified and the qualified audit opinion regarding compliance for major programs. 5) Continuous Improvement: Lastly, we are committed to continuous improvement in our financial reporting processes to maintain the highest standards of transparency and accountability. We remain confident in the strength of our underlying business operations and our longterm growth prospects. The material weaknesses identified and the qualified audit opinion regarding compliance for major programs does not impact our ability to operate effectively or our financial stability. We have made internal changes and are working with consultants to make improvements to our system. We appreciate the ongoing support of our board, employees, and stakeholders as we work diligently to implement the necessary improvements highlighted by the audit process.

View Audit 318109

Finding 485374 (2022-002)

Material Weakness 2022

So Consortium

OH

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding Reference Number: 2022-002 Name of Responsible Person: Steve Sturgill, Executive Director Reporting Views of Responsible Officials: We concur that the Organization does not properly monitor the amounts recorded in the Schedule of Expenditures of Federal Awards to ensure that schedule is comp...

Finding Reference Number: 2022-002 Name of Responsible Person: Steve Sturgill, Executive Director Reporting Views of Responsible Officials: We concur that the Organization does not properly monitor the amounts recorded in the Schedule of Expenditures of Federal Awards to ensure that schedule is complete and accurate. Concur or Do Not Concur with this Finding: Concur Agree or Disagree with Auditor Recommendations: Agree Completion Date of Proposed Completion Date: October 31, 2024 Actions Taken or Planned on this Finding: We acknowledge the material weaknesses identified in the financial statements and related to federal awards as well as the qualified audit opinion issued by Tidwell regarding our compliance for the major programs for the year ended October 31, 2022. The material weaknesses identified and the qualified audit opinion on compliance for the major programs indicates that while the financial statements -provide a true and fair view of our financial position, there are specific areas that require attention and improvement. We appreciate the thoroughness of the audit process conducted by Tidwell Group, LLC, which has provided valuable insights into our financial reporting practices. In response to the material weaknesses identified and the qualified audit opinion regarding compliance for major programs, we are committed to addressing the concerns raised by the auditors. Our immediate steps include: 1) Reviewing Accounting Policies: We will review and possibly revise our accounting policies to ensure they are aligned with industry standards and regulatory requirements. 2) Enhancing Internal Controls: We recognize the importance of robust internal controls. Therefore, we will strengthen our internal control mechanisms to mitigate risks and ensure the accuracy of financial reporting. 3) Improving Financial Reporting Practices: We will enhance our financial reporting practices to provide more transparent and comprehensive disclosures. 4) Engaging with Stakeholders: We will communicate openly with our stakeholders, including board members, regulators, and creditors, to address any concerns arising from the material weaknesses identified and the qualified audit opinion regarding compliance for major programs. 5) Continuous Improvement: Lastly, we are committed to continuous improvement in our financial reporting processes to maintain the highest standards of transparency and accountability. We remain confident in the strength of our underlying business operations and our longterm growth prospects. The material weaknesses identified and the qualified audit opinion regarding compliance for major programs does not impact our ability to operate effectively or our financial stability. We have made internal changes and are working with consultants to make improvements to our system. We appreciate the ongoing support of our board, employees, and stakeholders as we work diligently to implement the necessary improvements highlighted by the audit process.

View Audit 318109

Finding 485178 (2022-003)

Significant Deficiency 2022

County of Caldwell

TX

Subrecipient Monitoring

The County Auditor’s office receives and reviews the fifteen (15) agency bank accounts on a monthly basis from various departments. An action plan includes identifying the fund and/or department/division these agency accounts will be appropriated and/or allocated.

View Audit 317989

Finding 485014 (2022-005)

Significant Deficiency 2022

County of Lycoming, Pennsylvania

PA

Subrecipient Monitoring Reporting Special Tests & Provisions

Finding 2022-005 – Completion and Submission of Annual Single Audit – Significant Deficiency/Non-Compliance Corrective Action: The Budget and Finance Office is comprised of a limited number of accountants. The Budget & Finance offices has also been struggling with staffing shortages that have dela...

Finding 2022-005 – Completion and Submission of Annual Single Audit – Significant Deficiency/Non-Compliance Corrective Action: The Budget and Finance Office is comprised of a limited number of accountants. The Budget & Finance offices has also been struggling with staffing shortages that have delayed certain reporting requirements. County Management is working to obtain proper staffing levels and skillset within the Department of Budget and Finance so that audit responsibilities are completed within prescribed timeframes. Responsible for Implementing Corrective Action: Department of Budget & Finance

View Audit 317804

Finding 485013 (2022-004)

Significant Deficiency 2022

County of Lycoming, Pennsylvania

PA

Subrecipient Monitoring § 200.331 § 200.521

Finding 2022-004 – Uniform Guidance Subrecipient Monitoring – Significant Deficiency/Non-Compliance Corrective Action: The County has met with Children & Youth to discuss in detail the process of monitoring Title IV-E activities. As a result of such, a formalized plan was implemented including a Su...

Finding 2022-004 – Uniform Guidance Subrecipient Monitoring – Significant Deficiency/Non-Compliance Corrective Action: The County has met with Children & Youth to discuss in detail the process of monitoring Title IV-E activities. As a result of such, a formalized plan was implemented including a Sub-Recipient Monitoring Agreement for FY 2022-2023. Responsible for Implementing Corrective Action: Budget & Finance, Purchasing Joinder Board

View Audit 317804

Finding 484748 (2022-002)

Material Weakness 2022

Little Rock Workforce Development Board

AR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.331

Management is consiering its options for further appeals to the department of Labor for review. Management will work to ensure proper policies and procedures are established and followed by December 31, 2024

View Audit 317675 Questioned Costs: $1

Finding 484631 (2022-004)

Material Weakness 2022

Corporacion Del Centro De Bellas Artes De Puerto Rico

PR

Subrecipient Monitoring Material Weakness Reporting § 200.512

Action Item Title 2022-004 – Reporting Compliance Requirement Reporting Status (Open: In-process) Condition: Pass-Through Entity Reporting Requirements – The Corporation submitted just two reports during the year, the first and second required submission. Single Audit Reporting Packages – The ...

Action Item Title 2022-004 – Reporting Compliance Requirement Reporting Status (Open: In-process) Condition: Pass-Through Entity Reporting Requirements – The Corporation submitted just two reports during the year, the first and second required submission. Single Audit Reporting Packages – The Corporation did not comply with the Single Audit Reporting Package submission requirements for the years ended June 30, 2022, and 2023. Identified root cause: Lack of understanding of reporting compliance requirements for federal awards. Fiscal year 2022 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs. Grantee resolution plan: Pass-Through Entity Reporting Requirements – On July 1, 2022, the Corporation began submitting the monthly requested reports, subject to the Puerto Rico Fiscal Agency and Financial Advisory (AAFAF, as its Spanish acronym), the pass-through entity, required guidelines when funds are obligated. Single Audit Reporting Packages – The Corporation will submit the outstanding Single Audit Reporting Packages. Completion Date: Pass-Through Entity Reporting Requirements - Corrected Single Audit Reporting Packages – August 2024 Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

View Audit 317516

Finding 484630 (2022-003)

Significant Deficiency 2022

Corporacion Del Centro De Bellas Artes De Puerto Rico

PR

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.327

Action Item Title 2022-003 – Procurement Policies and Covered Transactions Compliance Requirement Procurement, Suspension, and Debarment Status (Open: In-process) Condition: General Procurement Standards - Written Policies – The Corporation has an outdated institutional procurement manual appr...

Action Item Title 2022-003 – Procurement Policies and Covered Transactions Compliance Requirement Procurement, Suspension, and Debarment Status (Open: In-process) Condition: General Procurement Standards - Written Policies – The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements. Suspension and Debarment - Covered Transaction – From a population of nineteen disbursements, we selected nine disbursements to ascertain compliance with 2 CFR section 180.220 by examining the procurement documents provided by the Corporation. From that sample, we identified nine instances in which the SAM.gov registration verification process was not performed. Of the nine instances, we found eight suppliers properly registered, but one supplier appears as validated as unique and existing but not registered in SAM.gov. Identified root cause: Lack of understanding of procurement compliance requirements for federal awards. Fiscal year 2023 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs Grantee resolution plan: General Procurement Standards - Written Policies – With the implementation of Law No. 73 of 2019, previous processes established by regulation are repealed and rendered ineffective. In addition, the Corporation will adopt procurement policies in compliance with the federal regulations. Suspension and Debarment - Covered Transaction - Currently, the Corporation is verifying and requesting all suppliers with contracts of $25,000 and over with evidence of being active at SAM.gov. Also, the Corporation is verifying if the supplier is suspended or debarred to do business with the Federal government. Completion Date: General Procurement Standards - Written Policies – By June 30, 2025 Suspension and Debarment - Covered Transaction – Corrected in FY2023. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

View Audit 317516

Finding 481175 (2022-002)

Significant Deficiency 2022

Regional Office of Education #47

IL

Subrecipient Monitoring § 200.303 § 200.332

FINDING NO: 2022-002 - Subrecipient Monitoring (Repeated from Prior Year Findings 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: Audit procedures revealed that ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards as follows: McKinney Educa...

FINDING NO: 2022-002 - Subrecipient Monitoring (Repeated from Prior Year Findings 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: Audit procedures revealed that ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards as follows: McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. COVID-19 ARP - McKinney Education for Homeless Children – for two (2) of two (2) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. PLAN: Moving forward, The Regional Office will formally identify the subaward and applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2025 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

View Audit 317273

Finding 481150 (2022-014)

Material Weakness 2022

Unity Health Care, Inc.

MD

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Management Response #2022-014: Due to software update with DC Department of Health, the January 1 – March 31, 2022, records were not available, nor were internal reviews of eligibility requirements support available as required. Corrective Action Plan: • The Grants program management team will expa...

Management Response #2022-014: Due to software update with DC Department of Health, the January 1 – March 31, 2022, records were not available, nor were internal reviews of eligibility requirements support available as required. Corrective Action Plan: • The Grants program management team will expand upon our current process to ensure eligibility determination is verified and documented. • Training will be provided to staff on performing income eligibility verification to include taking a screen shot of the eligibility and storing it on a protected shared drive with a de-identified naming convention. This will allow us to have a warehouse of the eligibility verification that can be referenced when needed. It shall be maintained by the WIC Director with limited access and password protection. Policy/procedure manuals for the WIC Dept will be updated to reflect this new requirement and ensure compliance. Responsible Party: Tracy Harrison, COO

View Audit 317252

Finding 481132 (2022-013)

Significant Deficiency 2022

Unity Health Care, Inc.

MD

Subrecipient Monitoring § 200.303 § 200.322

Management Response #2022-013: Due to staff turnover in prior years and inadequate handover procedures, the Subrecipient Monitoring was not done as required. Corrective Action Plan: The Grants program management team has developed a Title X Program Manual to include a clearer Subrecipient Monitorin...

Management Response #2022-013: Due to staff turnover in prior years and inadequate handover procedures, the Subrecipient Monitoring was not done as required. Corrective Action Plan: The Grants program management team has developed a Title X Program Manual to include a clearer Subrecipient Monitoring process that includes regular site visits and requiring supporting documentation of expenses. Furthermore, the Grants program management team will report out to the applicable internal parties on status of visits and findings on a quarterly basis. Responsible Party: Erin Flior, CDSO

View Audit 317252

Finding 481117 (2022-009)

Material Weakness 2022

Unity Health Care, Inc.

MD

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.305

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, wh...

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The following action plans have since been implemented: • During the fourth quarter in 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • During the fourth quarter in 2022 a new process was implemented to track grant related activities. Prior to any drawdown, the expenses are pulled from the G/L and reviewed. The expenses are entered into a spreadsheet and totaled based on the applicable federal award which has been assigned a client ID in the accounting system. The finance team is notified of the amount due to be drawn for each federal award. That amount is entered into the accounting system as an accounts receivable entry. This process has been formally documented. • Project Budget Reports have been created for each federal award. These reports include the budget, expenses for each month and the revenue (drawdown) incurred for each month. The reports will be reviewed and reconciled by the grants administration staff and finance monthly to ensure all agree with the allocated costs and costs and are in compliance with grant regulations. Once approved by both teams the reports will be routed for signatures. This process was launched in July 2022. • Supporting documentation for all draws will be maintained on a shared network drive so that an adequate audit trail will be established. This drive will be backed up on a regular basis by the Information Technology team. Responsible Party: Tamara Barnes, CFO

View Audit 317252

Finding 481107 (2022-009)

Significant Deficiency 2022

National Casa Association

WA

Subrecipient Monitoring Reporting § 200.303

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update FFATA reporting procedures to document and maintain documentation of Supervisory review and approval of FFATA data preparation. Completion Date: March 29, 2023 Explanation: Management c...

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update FFATA reporting procedures to document and maintain documentation of Supervisory review and approval of FFATA data preparation. Completion Date: March 29, 2023 Explanation: Management concurs that although it already enhanced policies to comply with an OJJDP/OCFO recommendation resolved in 2023, which included a two-step review and approval process for subrecipient awards involving the Executive Team, grantor procedures will be updated as recommended to include a third step to specify review and approval of subrecipient FFATA data prior to submission. The Supervisor or member of the Executive Team will capture review and approval of FFATA data with an email including the approved list attached. When FFATA reporting is submitted by staff, the list will be updated with the date submitted and returned to the Supervisor to confirm timeliness. Regarding the 12 subrecipient awards for Court Appointed Special Advocates selected for testing FFATA submission requirements, 9 out of 12 reports were submitted by the last day of the month following the start of the grant period.

View Audit 317239

Finding 481103 (2022-008)

Significant Deficiency 2022

National Casa Association

WA

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to specify documentation and maintenance of such documentation of the review and approval of costs allocated to federal grants within the grant funding period. 2) Update grant policies to include subrecipient periodic s...

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to specify documentation and maintenance of such documentation of the review and approval of costs allocated to federal grants within the grant funding period. 2) Update grant policies to include subrecipient periodic submission of supporting documentation. Completion Date: July 10, 2024 Explanation: Management concurs that the procedures should specify documentation and maintenance of such documentation of the review and approval of costs allocated/charged to the federal grant within the grant funding period. Grant policies and procedures have been updated to include subrecipient periodic submission of general ledger or other financial documentation supporting expenditures during the period.

View Audit 317239

Finding 481099 (2022-007)

Significant Deficiency 2022

National Casa Association

WA

Subrecipient Monitoring Reporting § 200.512

Responsible: Thomas Hoover, CFO Corrective Actions: Upload the 2022 reporting package to the Federal Audit Clearinghouse. Completion Date: August 14, 2024 Explanation: Management concurs that the reporting package was not submitted to the Federal Award Clearinghouse within the deadline due to t...

Responsible: Thomas Hoover, CFO Corrective Actions: Upload the 2022 reporting package to the Federal Audit Clearinghouse. Completion Date: August 14, 2024 Explanation: Management concurs that the reporting package was not submitted to the Federal Award Clearinghouse within the deadline due to the completion of the closeout of a joint OJJDP/OCFO October 2022 monitoring visit report that resulted in a delay in the FY22 Single Audit being conducted and completed.

View Audit 317239

Finding 481093 (2022-005)

Significant Deficiency 2022

National Casa Association

WA

Subrecipient Monitoring § 200.1 § 200.332 § 200.405 § 200.414

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update subrecipient award agreements to ensure the final approved scope of work or project description is specified. Completion Date: March 29, 2023 Explanation: Policies and procedures were ...

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update subrecipient award agreements to ensure the final approved scope of work or project description is specified. Completion Date: March 29, 2023 Explanation: Policies and procedures were updated in 2023 in response to an OJJDP/OCFO recommendation to ensure subaward files contain the requisite components for the award agreement. In addition to these updates, which include a master file checklist, National CASA/GAL has updated the subrecipient Terms & Conditions agreement to include CFR requirements as recommended.

View Audit 317239

Finding 481085 (2022-003)

Material Weakness 2022

National Casa Association

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.430

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to document and maintain the documentation of Supervisory review and approval of journal entries charging payroll costs to federal grants; 2) Update Finance policies to review estimates of accrued costs charged to feder...

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to document and maintain the documentation of Supervisory review and approval of journal entries charging payroll costs to federal grants; 2) Update Finance policies to review estimates of accrued costs charged to federal grants at calendar/fiscal year end to determine whether true-ups to actual costs are necessary. Completion Date: March 29, 2023 Explanation: 1) Review of allocated payroll costs: Payroll processing and recording of costs charged to federal grants has in practice, consistently involved multiple review and approval steps by at least two employees. Detailed records of these steps are maintained in Finance records for each payroll, including the allocated grant costs. However, Management acknowledges that an additional step be added to capture the documentation of review and approval of the payroll journal entries that allocate payroll costs to federal grants. This step was put in place in 2023 to resolve a recommendation from OJJDP/OCFO. Supervisor review and approval is captured directly in the general ledger system. Finance policies have been updated to codify this additional step as recommended. 2) Procedure for trueing up estimates: Three of sixty transactions tested showed that payroll costs were accrued at year end based on the approved grant budget but were not trued up in the new accounting period based on actual costs. The total variance of the three transactions was $6.20. Finance policies have been updated to include evaluating year-end accruals to determine whether a true-up is necessary in the new period as recommended.

View Audit 317239

Finding 481081 (2022-002)

Significant Deficiency 2022

National Casa Association

WA

Subrecipient Monitoring Reporting

Responsible: Sally Erny, Deputy CEO Corrective Action: Document and maintain documentation of Supervisory review and approval of grant reports. Completion Date: July 10, 2024 Explanation: Since the inception of National CASA/GAL receiving federal funding, procedures and practices were in place f...

Responsible: Sally Erny, Deputy CEO Corrective Action: Document and maintain documentation of Supervisory review and approval of grant reports. Completion Date: July 10, 2024 Explanation: Since the inception of National CASA/GAL receiving federal funding, procedures and practices were in place for the review and approval of performance reports and SF-425s (FFRs). This practice includes the involvement of multiple staff in the organization participating in the development and review of these documents and a knowledgeable staff member with appropriate authority approving the document. There are many points of approval through the development of the reports. In terms of the FFRs, the Accounting Director is responsible for preparing a Pivot table showing the expenses for the grant for both the quarterly and inception to date periods and to update the data worksheet for the quarterly FFR report. The Controller confirms that the cumulative expenses indicated on the quarterly FFR report data worksheet match the inception to date information in the accounting ledger and then approves the report. The Accounting Director submits the FFR report through the Grants Management System. In 2023 a policy, as part of the Operations SOPs, was put in place that in addition to the various staff who work on developing the performance report, OJJDP performance reporting would be reviewed and approved and documented as such, by the Project Manager and appropriate Chief Officer. This policy formalized what had been happening in practice over many years. While we acknowledge that this policy of documentation was not in place in 2022, the practice of review and approval was. In 2023 and going forward, we have improved documenting the approval processes for the FFRs and performance reports.

View Audit 317239

Finding 480993 (2022-002)

Material Weakness 2022

Brookfield Local School District

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.414 § 200.502 § 200.510

All future federal expenditures will be reconciled to the disbursement ledger.

View Audit 317104

Finding 480515 (2022-001)

Material Weakness 2022

Virginia Commonwealth University Health System

VA

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Timely Preparation of Schedule of Expenditures of Federal Awards (SEFA) COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s policy and procedure should be designed to ensure timely reporting as required by the Uniform Guidance. Explanation of disagreeme...

Timely Preparation of Schedule of Expenditures of Federal Awards (SEFA) COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s policy and procedure should be designed to ensure timely reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will enhance its procedures around the preparation of the SEFA to include a timely year-end reconciliation between the general ledger and all source documentation to ensure that all Federal expenditures are complete and accurately reported in the SEFA in fiscal 2024. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: For the creation of the Schedule for FY2023.

View Audit 316712

Finding 480333 (2022-005)

Material Weakness 2022

City of Manteca

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding #SA2022-005 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California Stat...

Finding #SA2022-005 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure all documentation is provided for contracts and subcontracts. • Anticipated Completion Date: 06/30/24

View Audit 316559

Finding 479749 (2022-005)

Material Weakness 2022

Cambria Heights School District

PA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.302

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office o...

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to enhance its internal controls for tracking and monitoring federal program expenditures and to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

View Audit 316303

Finding 479637 (2022-010)

Significant Deficiency 2022

Municipality of Anchorage, Alaska

AK

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2022-010 Procurement and Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contr...

Finding 2022-010 Procurement and Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place. Anticipated Completion Date: December 31, 2024

View Audit 316214

Finding 479634 (2022-009)

Material Weakness 2022

Municipality of Anchorage, Alaska

AK

Subrecipient Monitoring § 200.332 § 200.501

Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and proc...

Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring. Anticipated Completion Date: December 31, 2024

View Audit 316214

Corrective Action Plans

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