Corrective Action Plans

Finding 60395 (2022-001)

Material Weakness 2022

WA

Procurement, Suspension & Debarment School Nutrition Programs Subrecipient Monitoring

The District will include the SAM.gov check on all purchases made using Federal funds on a purchase order (PO). Supporting documentation will be retained. This verification will occur prior to any payment being made. The District will ensure that POs are signed by vendors/contractors indicating t...

The District will include the SAM.gov check on all purchases made using Federal funds on a purchase order (PO). Supporting documentation will be retained. This verification will occur prior to any payment being made. The District will ensure that POs are signed by vendors/contractors indicating their non-suspended and non-debarred status, affirming their eligibility to participate in the procurement process.

View Audit 55808

Finding 60393 (2022-003)

Significant Deficiency 2022

County of Orange, California

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in...

Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Management Response and Corrective Action: County Executive Office: 1. Person Responsible: Selina Chan-Wychgel, Fiscal Services Manager 2. Corrective Action Plan: The County Executive Office will adhere to the Contract Policy Manual (CPM) and internal policy and procedure of ensuring the suspension or debarment verification of a contractor is performed and documented prior to awarding a contract. The County Procurement Office will continue to provide trainings and reminders to County-wide procurement staff of this guideline to ensure compliance with Federal Award protocol. 3. Anticipated Implementation date: June 30, 2023 OC Public Works: 1. Person Responsible: Joseph Sly 2. Corrective Action Plan: On October 21, 2022, OCPW Procurement updated the Department?s policy and procedure to include an additional requirement for the submission of the Alternative Funding Procurement Acknowledgement Form when utilizing non-County funding sources. The contracts selected in this audit were awarded prior to October 21, 2022. 3. Anticipated Implementation date: October 21, 2022

View Audit 56545

Finding 60392 (2022-001)

Material Weakness 2022

County of Orange, California

CA

Reporting Subrecipient Monitoring Material Weakness

Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance an...

Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Management Response and Corrective Action: Auditor Controller: 1. Person Responsible: Bertalicia Tapia, Financial Reporting & Mandated Costs (FRMC) Manager 2. Corrective Action Plan: While the County reconciles the Project and Expenditure Reports filed with the US Treasury to the County?s accounting records, a temporary difference between the reported amounts on the SEFA and US Treasury reports was caused by a one-time permitted adjustment to reallocate expenditures for government services subsequent to filing the US Treasury reports. While currently in compliance with US Treasury reporting guidelines, the County will reflect the permitted adjustment on its subsequent quarterly Project and Expenditure Report due to the US Treasury on April 30, 2023. 3. Anticipated Implementation date: April 30, 2023

View Audit 56545

Finding 60381 (2022-004)

Significant Deficiency 2022

County of Orange, California

CA

Subrecipient Monitoring § 200.332

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient...

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Management Response and Corrective Action: Sheriff-Coroner?s Department: 1. Person Responsible: Yumi Leung, Supervising Grants Manager 2. Corrective action plan: The Sheriff-Coroner Department will complete a pre-award risk assessment form at the time the subrecipient is notified of a subaward. The Sheriff-Coroner Department resumed subrecipient monitoring visits starting January 2023. Going forward, if on-site visits are not possible, virtual meetings with subrecipients will be conducted. 3. Anticipated Implementation date: June 2023

View Audit 56545

Finding 60350 (2022-006)

Significant Deficiency 2022

County of Orange, California

CA

Subrecipient Monitoring Procurement, Suspension & Debarment Significant Deficiency

Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring...

Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, the SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient Monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Karen Vu, Administrative Manager II, Contract Services 2. Corrective action plan: A checklist will be developed listing all the required documentation to be completed, including the SAM clearance check, prior to entering into a contract with a vendor. Contracts staff will be required to complete the checklist prior to entering into a contract with a vendor and maintain documentation of the verification in the Contracts file. 3. Anticipated Implementation date: July 1, 2023

View Audit 56545

Finding 60349 (2022-005)

Significant Deficiency 2022

County of Orange, California

CA

Subrecipient Monitoring § 200.331

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financia...

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the SSA department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Management Response and Corrective Action: Sheriff-Coroner?s Department: 1. Person Responsible: Yumi Leung, Supervising Grants Manager 2. Corrective action plan: The Sheriff-Coroner Department will identify on future subaward letters whether the award is research and development, and whether there is an indirect cost rate for the federal award. 3. Anticipated Implementation date: June 2023 Social Services Agency: 1. Person Responsible: Karen Vu, Administrative Manager II, Contracts Services 2. Corrective action plan: SSA will revise the current Subrecipient Monitoring Policy and Procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). A check list will be developed to track activities and ensure that the required award information and applicable requirements were communicated to subrecipients. 3. Anticipated Implementation date: July 1, 2023

View Audit 56545

Finding 60348 (2022-002)

Material Weakness 2022

County of Orange, California

CA

Subrecipient Monitoring § 200.332 § 200.501

Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitorin...

Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d) ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow- up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Kristi Fiskum, Deputy Division Director, Family Assessment & Shelter Services and Karen Vu, Administrative Manager II, Contracts Services 2. Corrective action plan: SSA will revise its current Subrecipient Monitoring Policy in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. SSA will include procedures for verifying that every subrecipient is audited and a monitoring checklist will be developed to track activities. 3. Anticipated Implementation date: July 1, 2023

View Audit 56545

Finding 60346 (2022-007)

Significant Deficiency 2022

County of Orange, California

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.334

Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of ...

Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Management Response and Corrective Action: Health Care Agency: 1. Person Responsible: Joshua Jacobs, HCA Public Health Services - Communicable Disease Control Division Director 2. Corrective action plan: HCA Public Health Services Communicable Disease Control Division will ensure retention of proper documentation supporting the performance reports and substantiating the review/approval prior to report submission to the State for the Immunization Cooperative Agreement. 3. Anticipated Implementation date: March 27, 2023

View Audit 56545

Finding 60333 (2022-001)

Significant Deficiency 2022

Saint Francis University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.268, 84.063 Federal Award ...

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.268, 84.063 Federal Award Year: June 30, 2022 Corrective Action Taken The University?s Interim Financial Aid Director, Stephanie Schrift, has required all Student Financial Services staff to attend virtual trainings on the return of Title IV funds process in April 2023. In addition, Stephanie Schrift (Interim Director) will process all R2T4s via COD's calculator and Elizabeth Susick (Assistant Director) will verify and sign off on the calculations once complete. This will provide a two-step validation procedure for all R2T4 returns.

View Audit 54570

Finding 60322 (2022-006)

Significant Deficiency 2022

Women's Housing and Economic Development Corporation

NY

Subrecipient Monitoring Reporting

2022-006: Preparation of Schedule of Federal Awards Management will identify a permanent CFO or engage a consulting firm to provide CFO services to ensure that this expertise is available during the 2023 audit. Status of Finding: Management has already put a plan in place to resolve the finding duri...

2022-006: Preparation of Schedule of Federal Awards Management will identify a permanent CFO or engage a consulting firm to provide CFO services to ensure that this expertise is available during the 2023 audit. Status of Finding: Management has already put a plan in place to resolve the finding during fiscal year 2023 and will continue to work on resolving the finding. Managements Response: Management agrees with the finding.

View Audit 56009

Finding 60304 (2022-012)

Significant Deficiency 2022

City of Detroit, Michigan

MI

Subrecipient Monitoring Reporting Period of Performance § 200.1 § 200.331 § 200.332 § 200.414

Finding Number: 2022-012 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Condition: Original Finding Description: The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listi...

Finding Number: 2022-012 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Condition: Original Finding Description: The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN) as required per 2 CFR 200.332 (a)(1)(xii). Contact Person Responsible for Corrective Action: Sandra Yu Stahl and Terri Daniels Anticipated completion date: July 2023 Planned Corrective Action: The City has implemented a process to ensure that all subrecipient agreements contain the Federal ALN as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.

View Audit 49776

Finding 60273 (2022-007)

Material Weakness 2022

City of Detroit, Michigan

MI

Subrecipient Monitoring Eligibility Material Weakness § 200.303

Finding Number: 2022-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) and COVID-19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing, instances of...

Finding Number: 2022-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) and COVID-19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Contact Person Responsible for Corrective Action: Denise Fair and Angelique Tomsic Anticipated completion date: July 2023 Planned Corrective Action: In FY23, the City implemented a review of 100% of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The city will also continue to work with its contractor on process improvements. In addition, as part of the AFCAP process, the City will work with the department to perform internal reviews to help ensure processes are being followed

View Audit 49776

Finding 60264 (2022-014)

Material Weakness 2022

City of Detroit, Michigan

MI

Reporting Subrecipient Monitoring

Finding Number: 2022-014 Federal Program, Assistance Listing Number and Name: ALN 14.218, Department of Housing and Urban Development, Community Development Block Grants Cluster Condition: Original Finding Description: During reporting testing, we noted that the City did not file three FFATA reports...

Finding Number: 2022-014 Federal Program, Assistance Listing Number and Name: ALN 14.218, Department of Housing and Urban Development, Community Development Block Grants Cluster Condition: Original Finding Description: During reporting testing, we noted that the City did not file three FFATA reports and there were five untimely submissions. Contact Person Responsible for Corrective Action: Julie Schneider and Kelly Vickers Anticipated completion date: July 2023 Planned Corrective Action: In fiscal year 22 The city created and implemented a Federal Funding Accountability and Transparency Act (FFATA) SOP that included Roles and Responsibilities, and process requirements. Management will finalize the rollout of the policy and implement additional controls to help ensure the FFATA filing requirements are met and reporting is timely and accurate. In addition, the city will review during the AFCAP process to further ensure reporting is performed timely and accurately.

View Audit 49776

Finding 60260 (2022-006)

Material Weakness 2022

City of Detroit, Michigan

MI

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding Number: 2022-006 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City of Detroit did not have adequate controls in place to ex...

Finding Number: 2022-006 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City of Detroit did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Contact Person Responsible for Corrective Action: Denise Fair Anticipated completion date: July 2023 Planned Corrective Action: The City will implement controls to ensure that Health Department provides oversight of the contractor and the participant eligibility process. The Health Department has hired a WIC Program Director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed. Through the AFCAP project process, the City will also review the contract in detail to help ensure full compliance

View Audit 49776

Finding 60174 (2022-001)

Significant Deficiency 2022

Dock Manor INC

PA

Subrecipient Monitoring Eligibility HUD Housing Programs

Management has reviewed the process for recertifications and have contracted with a HUD qualified technical resource person to review, correct if necessary, and advise to ensure timely recertifications.

View Audit 56063

Finding 60100 (2022-002)

Significant Deficiency 2022

Marshall University Research Corporation

WV

Questioned Costs Subrecipient Monitoring Significant Deficiency

Department of Education, National Science Foundation, Department of Health and Human Services 2022-002 Federal program title: Research & Development Cluster, IDEA Cluster, Opioid STR Federal Assistance Listing Number: 47.074, 84.027, 93.279, 93.788 Condition: Marshall University's indirect cost rate...

Department of Education, National Science Foundation, Department of Health and Human Services 2022-002 Federal program title: Research & Development Cluster, IDEA Cluster, Opioid STR Federal Assistance Listing Number: 47.074, 84.027, 93.279, 93.788 Condition: Marshall University's indirect cost rate agreement contains percentages to be applied to direct costs to claim as indirect costs and fringe benefit rates that are to be applied to salaries and wages of employees charged to federal grants. During testing it was noted that for the period of April 1, 2022 to June 30, 2022, an incorrect indirect cost rate percentage and fringe rate was used to calculate indirect costs charged to federal grants. Recommendation: MURC should implement a control to establish an ongoing review process of the fringe benefit rates being charged to grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : MURC will review all Marshall University payroll reimbursement requests from all MURC grants to ensure the fringe benefit rates applied by the University are the correct rates for the fiscal year in which the salary expenses occur. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood and Rebekah Duke Planned completion date for corrective action plan: September 30, 2022 If the US Department of Health and Human Services has questions regarding this plan, please call Jennifer Wood at 304-696-2829.

View Audit 54850 Questioned Costs: $1

Finding 60098 (2022-002)

Material Weakness 2022

Dekalb County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Susan Sleeper Contact Phone Number: 260-925-2362 Views of Responsible Official: I concur with the finding. Description of Corrective Action Plan: New internal controls will be implemented for the suspension and debarment requirements...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Susan Sleeper Contact Phone Number: 260-925-2362 Views of Responsible Official: I concur with the finding. Description of Corrective Action Plan: New internal controls will be implemented for the suspension and debarment requirements. Auditor Sleeper has all conversed with County Attorney Kruse on the issue. Anticipated Completion Date: 06/30/2023

View Audit 54438

Finding 60080 (2022-001)

None 2022

County of Siskiyou

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Program Income

2022-001 Community Development Block Grants/State?s Program and Non-Entitlement in Hawaii We recommend that the County develop a program to monitor compliance with the loan provisions in accordance with the County Loan Servicing Policies and Procedures. Management?s Response: The County concurs wi...

2022-001 Community Development Block Grants/State?s Program and Non-Entitlement in Hawaii We recommend that the County develop a program to monitor compliance with the loan provisions in accordance with the County Loan Servicing Policies and Procedures. Management?s Response: The County concurs with the recommendation. Responsible Individual: Diane Olson, Auditor-Controller Corrective Action Plan: We will implement a process to review loan documents. Anticipated Completion Date: June 30, 2023

View Audit 56168

Finding 60058 (2022-005)

None 2022

Cobb County Government

GA

Subrecipient Monitoring Reporting

Views of Responsible Officials and Planned Corrective Actions: The County agrees with this recommendation and will continue to work with various departments, consultants and subrecipients to ensure the reporting submissions include all required data.

View Audit 55856

Finding 60050 (2022-004)

None 2022

Cobb County Government

GA

Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and will work with the Purchasing Department to ensure acceptable verification has been addressed. We will also discuss additional review procedures with the responsible departments for all cont...

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and will work with the Purchasing Department to ensure acceptable verification has been addressed. We will also discuss additional review procedures with the responsible departments for all contract awards with federal funding.

View Audit 55856

Finding 60035 (2022-003)

None 2022

Cobb County Government

GA

Subrecipient Monitoring § 200.330 § 200.332

Views of Responsible Officials and Planned Corrective Actions: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

View Audit 55856

Finding 60025 (2022-002)

None 2022

Cobb County Government

GA

Questioned Costs Subrecipient Monitoring Period of Performance § 200.77

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and has discussed additional review procedures with the subrecipients. In addition, the County created a Grants Division with increased staffing that can help provide monitoring throughout the y...

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and has discussed additional review procedures with the subrecipients. In addition, the County created a Grants Division with increased staffing that can help provide monitoring throughout the year.

View Audit 55856 Questioned Costs: $1

Finding 59981 (2022-002)

None 2022

Town of Wareham

MA

Equipment & Real Property Management Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The Town of Wareham, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Q...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The Town of Wareham, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425W 2022-002: Controls for the Purchasing of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Internal Control over Compliance ? Other Matter Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The Town did not have an adequate process to ensure that personnel responsible for grant compliance were aware of the need to obtain prior approval from the pass-through entity for capital expenditures related to the acquisition of general or special purpose equipment. As a result of our audit procedures, we noted the acquisition of two HVAC chillers that were charged to the grant where prior approval was not obtained from the pass-through entity. Questioned Costs: The Town expended a total of $2.1 million in Education Stabilization Funds in 2022, of which $457,000 was charged to supplies, materials and contracted services accounts. Of the total charged to supplies, materials and contracted services accounts, $334,000 was selected for testing and $144,000 was spent on the purchase of two HVAC chillers without prior approval from the pass-through entity. Context: The Town used grant funds to purchase capital equipment without prior approval from the pass-through entity as required by federal and state guidelines. Effect: The Town is not in compliance with grant requirements for the acquisition of capital equipment. Cause: Lack of appropriate controls over charging expenditures to the grant, maintaining documentation for costs charged, and lack of knowledge over grant compliance requirements. The internal control process should include the education of personnel on grant compliance requirements and procedures to ensure that grant activity is spent in accordance with federal and state requirements. Recommendation: Management should implement internal controls to ensure that administrators are aware of all grant compliance requirements including the need to obtain prior written approval from the pass-through entity for capital expenditures paid from the Education Stabilization Fund grants. Views of Responsible Officials and Planned Corrective Actions: Management will implement internal controls to ensure that administrators are aware of all grant compliance requirements including the need to obtain prior written approval from the pass-through entity for capital expenditures paid from the Education Stabilization Fund grants. Management plans to implement these procedures in fiscal 2023. If the Oversight Agency has questions regarding this plan, please call Kristin Flynn, Director of Finance at Wareham Public Schools at 508-291-3500 or Derek Sullivan, Town Administrator at 508-291-3100. Sincerely yours, Kristin Flynn Director of Finance Wareham Public Schools Derek Sullivan Town Administrator Town of Wareham

View Audit 56635

Finding 59969 (2022-001)

Significant Deficiency 2022

Town of Wareham

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The Town of Wareham, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 ...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The Town of Wareham, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers 84.027 and 84.173 Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425W 2022-001: Controls for Monitoring Payroll Charged to the Grants Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The Town did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The Town has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2023. If the Oversight Agency has questions regarding this plan, please call Kristin Flynn, Director of Finance at Wareham Public Schools at 508-291-3500, or Derek Sullivan, Town Administrator at 508-291-3100. Sincerely yours, Kristin Flynn Director of Finance Wareham Public Schools Derek Sullivan Town Administrator Town of Wareham

View Audit 56635

Finding 59968 (2022-001)

None 2022

Middle Tyger Community Center

SC

Questioned Costs Subrecipient Monitoring Eligibility

Condition: Eligibility for ERAP1 required that individuals self-attest that they had a need for rental or utility assistance under the ERAP program. Eligibility is defined in the OMB's compliance supplement and guidance. Reason Improvement Needed: Eligibility is a key component of the ability of an...

Condition: Eligibility for ERAP1 required that individuals self-attest that they had a need for rental or utility assistance under the ERAP program. Eligibility is defined in the OMB's compliance supplement and guidance. Reason Improvement Needed: Eligibility is a key component of the ability of any Federal agency or funding recipient to disburse funds under the COVID-19 funding. The Center needs to ensure that eligibility is monitored and thoroughly checked to ensure individuals who are not eligible do not receive funding. Cause of Condition: The Center paid out funds as it was required by current guidance. ERAP1 was to be paid out on self-attestation standards allowing the affected renters the ability to "self-certify" that they were in need of the rental assistance and other utility assistance in order to gain access to the funds. When ERAP2 was administered, the guidance changed to require the Center to request and validate multiple types of support to ensure that the funds were necessary for the individual. Effect of Condition: Self attestation leaves the onerous of being truthful on the individual receiving the funds and takes the ability to deny one's funding for fraudulent reasons out of the hands of the Center. Perspective Information: We don't find this to be a systemic issue. The Center has complied with all types of eligibility testing requirements each year for the ERAP 1 and ERAP2 funding. The Center only identified the fraud during FY21 in the ERAP1 funding when the ERAP2 guidelines changed and some of the same individuals applied for the funding again. Identification of Repeat Findings: This is NOT a repeat finding from the prior year. Client Response: The Center has turned over the names and amounts of funds that were fraudulently gained from the ERAP1 program to the pass-through entity by which it received the original funding. The pass-through entity is the prosecuting entity who will determine how to properly move forward with the fraud claims. The Center has fulfilled its duty to report any fraud identified in the program.

View Audit 56435 Questioned Costs: $1

Corrective Action Plans

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