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Finding 47807 (2022-048)
Significant Deficiency 2022
State of Oregon
OR
Subrecipient Monitoring Reporting Significant Deficiency
2022-048 Oregon Health Authority Improve review of federal performance progress reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2...
2022-048 Oregon Health Authority Improve review of federal performance progress reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency Prior Year Finding: 2019-020 Questioned Costs: N/A Criteria: 45 CFR 75.303(a); 45 CFR 75.342(b); Opioid STR Notice of Awards Federal regulations require performance progress reports (reports) be submitted semi-annually and include an overview of the goals and objectives accomplished during the funding period as stated in the grants? funding opportunity announcements. In addition, federal regulations require award grantees to establish and maintain effective internal control that provides reasonable assurance the award is managed in compliance with regulations and terms and conditions of the award. Effective controls may include review and approval of reports for completeness and accuracy. The Health Systems Division of the Oregon Health Authority (department) developed a tool to document post award monitoring in March of 2020, and for three years, the department has pointed to this tool as an action taken to ensure reports are complete and accurate. Although the department has yet to implement this tool, we found evidence of other internal controls that were partially implemented. Program now utilizes collaborative online software called Smartsheet which allows a contracted evaluator to compile subrecipient performance data the department can monitor and edit in real time. The department uses the Smartsheet as support for progress report data. We found some key data elements in the SOR2 year 2 progress report did not agree to support in Smartsheet. Program stated they reviewed a different spreadsheet supplied by the evaluator, not Smartsheet, which had totals agreeing to the submitted report. However, the department did not retain this additional spreadsheet. Without retaining the underlying support used for review, we are unable to assess the effectiveness of the department?s review of the report prior to submission. Program now requires manager review of reports prior to submission. We found evidence of manager review of the SOR2 year 2 progress report, however it was dated two days after the report was submitted. Ineffective controls could result in a misrepresentation of the grant?s performance. We recommend department management implement internal controls to ensure performance progress reports are complete and accurate prior to report submission. MANAGEMENT RESPONSE: We agree with this recommendation. To ensure performance progress reports are complete and accurate prior to report submission, the department will review current internal controls and plans to implement revised or new controls. The current process steps we are reviewing include: ? Sending the completed report via email to the program manager requesting they review the report for completeness and accuracy. ? Documenting approval via email confirmation that the report is complete and accurate prior to submission to federal funders. There is a need to revisit the internal control of having only managers designated to review the federal performance progress reports; we plan to discuss having the following individuals designated to conduct this review: principal investigator, grant coordinator, active partner, or manager. Anticipated Completion Date: December 31, 2023 Contact: Kelsey Smith-Payne, Opioid SOR Grants Project Director and Sarah Adelhart, Interim Manager
View Audit 45093
Finding 47806 (2022-047)
Significant Deficiency 2022
State of Oregon
OR
Subrecipient Monitoring Reporting
2022-047 Oregon Health Authority Implement controls to comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020...
2022-047 Oregon Health Authority Implement controls to comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: 2019-019 Questioned Costs: N/A Criteria: 45 CFR 75.303(d); 45 CFR 75.351; 45 CFR 75.352(b) and (d) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk. Federal regulations also require grantees take prompt action when instances of noncompliance are identified in audit findings. The Health Systems Division of the Oregon Health Authority (department) developed a formal process for performing risk assessments to determine appropriate monitoring activities and developed a tool to document post award monitoring in March of 2020, and for three years, the department has pointed to these procedures as actions taken to partially correct the original 2019 finding. However, the department has yet to implement these or other procedures, and the Opioid program has no documented monitoring plan in place. Federal regulations require the department, as a pass-through entity, to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). Out of 75 contracts with 59 subrecipients, we reviewed 15 contracts with 10 subrecipients and based on the contracts? listed deliverables, we determined five of them did not appear to meet the definition of a subrecipient. Department management could not support its subrecipient determinations and could not identify who made the decisions. As a result, the SEFA may incorrectly report $751,911 as pass-through funds instead of direct expenditures. We recommend department management comply with subrecipient monitoring requirements by implementing and documenting a procedure that evaluates each subrecipient?s risk of noncompliance for the purpose of determining and performing the appropriate monitoring for each subrecipient. We also recommend department management implement procedures to ensure federal subrecipient versus contractor determinations result in accurate reporting on the SEFA. MANAGEMENT RESPONSE: We agree with this recommendation. To comply with subrecipient monitoring requirements, the authority will implement our documented procedures. We will evaluate subrecipient?s risk of noncompliance for the purpose of determining and performing the appropriate monitoring for each subrecipient. We will ensure each subrecipient completes the grantee self-risk assessment survey we?ve created; once completed and submitted this survey will generate a monitoring guidance document based on if the grantee was determined low, moderate, or high risk. This risk assessment survey and guidance document will help inform appropriate subrecipient monitoring. The auto-generated word document is emailed to the identified OHA staff, stored in the software?s report, and can be accessed by staff on an OHA intranet page (OWL site). Additionally, the authority will ensure accurate federal subrecipient versus contractor determinations. We will evaluate and improve current determination procedures, develop a comprehensive checklist or guidance document based on improvement recommendations, determine who has the primary responsibility for subrecipient determinations, and provide training as needed. Anticipated Completion Date: December 31, 2023 Contact: Kelsey Smith-Payne, Opioid SOR Grants Project Director and Sarah Adelhart, Interim Manager
View Audit 45093
Finding 47799 (2022-032)
Material Weakness 2022
State of Oregon
OR
Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.332
2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Fami...
2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6 , 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.332(a) ? (h) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward to determine the extent and scope of subrecipient monitoring activities. Monitoring activities should be based on the results of a given subrecipient?s determined risk. Pass-through entities must also communicate certain award information to subrecipients as the time of the subaward. The department, as the pass-through entity, has long-established subrecipient monitoring procedures broken into two categories: program and fiscal monitoring. Program monitoring is performed by program-specific staff and focuses on requirements related to certain aspects of Activities Allowed and Client Eligibility. During FY2022, the department performed program monitoring activities as planned. Fiscal monitoring reviews compliance requirements related to Allowable Costs, Activities Allowed, and Earmarking. However, fiscal monitoring activities were limited due to staff turnover. As a result, limited fiscal monitoring procedures were performed for 5 of 17 subrecipients, and fiscal monitoring risk assessments were not performed for any of the 17 subrecipients. Without the performance of subrecipient risk assessments and adequate fiscal monitoring, the department risks distributing program funds to subrecipients out of compliance with federal program requirements. Additionally, we reviewed 5 randomly selected subrecipients to determine whether all required grant award information was communicated at the time of the subaward. For all of the 5 subrecipients reviewed, only some of the required information was communicated at the time of the award. The required information missing in the original grant agreements was communicated via agreement amendments several months later. Without timely communication of required grant information, subrecipients may not have all the information they need for the subaward they received. We recommend department management ensure subrecipient risk assessments are performed for all subrecipients and ensure required fiscal monitoring activities are performed based on the results of the risk assessments. We also recommend department management ensure all required award information is communicated to subrecipients at the time of the subawards. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS lost critical fiscal monitoring staff and was unable to complete all risk assessments and fiscal monitoring due to this. OHCS is on track to complete fiscal monitoring and risk assessments for all subrecipients of LIHEAP in FY23. Additionally, OHCS has established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller or Michelle Cole, Assistant Director of Energy Services
View Audit 45093
Finding 47796 (2022-038)
Material Weakness 2022
State of Oregon
OR
Subrecipient Monitoring Material Weakness Reporting
2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Yea...
2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Special Test and Provisions Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: 2021-010, 2020-014, 2019-009 Questioned Costs: N/A Criteria: 45 CFR 261.61-62, 65 Federal regulations require each state maintain adequate documentation, verification, and internal control procedures to ensure the accuracy of data used in calculating work participation rates. Each state must have procedures to count and verify reported hours of work and must comply with its Work Verification Plan as approved by the U.S. Department of Health and Human Services (DHHS). Oregon?s Work Verification Plan outlines a system of controls for how reported hours will be verified and documented, and for reviews and monitoring procedures to identify errors. Work participation hours are reported via the quarterly Temporary Assistance for Needy Families (TANF) ACF-199 data reports and for benefits paid with designated state funds called maintenance of effort (MOE), the ACF-209 reports. As stated in a separate finding, titled `Ensure performance data reports are complete and accurate,? we determined the data reports are not complete or accurate. However, we found the department did correct a previous issue in which work participation hours on the ACF-199 report were left blank. Although reports were known to be incomplete, we reviewed the reporting periods October 1, 2021, through June 30, 2022, to test for compliance of the Work Verification Plan. We reviewed 20 randomly selected ACF-199 cases from a population of 16,249, and 20 randomly selected ACF-209 cases from a population of 146,324 of participating clients for verification of work activity participation. We found: Five of 20 ACF-199 cases with reported participation hours did not agree with hours in the system of record TRACS. 14 of 20 ACF-199 cases lacked support for the reported hours. 9 of 20 ACF-209 cases lacked support for the reported hours. These inaccurate or unverified hours were reported to DHHS for use in calculating the work participation rate. If the state fails to follow the approved Work Verification Plan, DHHS may penalize the state. We recommend TANF program management ensure the work participation rate is calculated appropriately using verified and accurate participation data in adherence to the department?s Work Verification Plan. We also recommend program management review the system of controls and identify where improvements are needed to ensure compliance with the work verification plan. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will develop training specific to error trends based on Quality Control audits of the JOBS program, skill enhancement/best practices on collecting and documenting accurate attendance, and technical training on the Department?s attendance documentation system, TRACS. The training will be instructor led and offered at minimum on a quarterly basis. The Department will review and edit tools, resources, and attendance logs to ensure compliance with the work verification plan. Updates made will be communicated to staff working with families receiving TANF. The Department will also form a workgroup to review the attendance documentation and case management system known as the Transition Referral and Client Self-Sufficiency (TRACS) system. The workgroup will make recommendations to developer, which will include system enhancements and edits to improve the process for staff. Anticipated Completion Date: April 30, 2024 Contact: Annette Palmer, TANF Program Manager
View Audit 45093
Finding 47787 (2022-045)
Significant Deficiency 2022
State of Oregon
OR
Subrecipient Monitoring Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303
2022-045 Oregon Health Authority Submit required FFATA reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements; 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases; 93.958 Bloc...
2022-045 Oregon Health Authority Submit required FFATA reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements; 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases; 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.268: 5 NH23IP922626; 6 NH23IP922626; 93.323: 6 NU50CK000541; 93.958: 1B09SM083823, 2021; 93.959: 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 170 Appendix A; 2 CFR 200.303 Federal regulations require recipients of federal awards to report certain subaward information in the FFATA Subaward Reporting System (FSRS) for subawards meeting the criteria for reporting. Reports must be submitted no later than the end of the month following the month in which the subawards were made. Federal regulations also require recipients of federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. We identified and reviewed the reporting status of all the department?s subawards subject to FFATA reporting during the audit period. We determined: Five of 30 Mental Health Block Grant (MHBG) subawards were not reported, totaling $4.2 million in obligations. 12 of 65 Substance Abuse Block Grant (SABG) subawards were not reported, totaling $6.2 million in obligations. Four of 37 Epidemiology and Laboratory Capacity (ELC) subawards were not reported, totaling almost $55.5 million in obligations. Five of 39 Immunization Cooperative Agreements subawards were not reported, totaling $6.3 million in obligations. Of the total not reported, one SABG, one ELC, and two Immunization subawards were not reported in the FSRS due to oversights in the department?s reporting process. The remaining unreported subawards resulted from the department?s suspension of FFATA reporting stemming from the federal replacement of the DUNS number with the Unique Entity Identifier (UEI) in May 2022. The department did not have UEI numbers for all subrecipients at the time of the replacement which prevented the department from submitting accurate reports. FFATA reporting was suspended through the end of state fiscal year 2022 and into the following state fiscal year. Although the department suspended FFATA reporting in the FSRS, a tracking spreadsheet was maintained that included all subaward award information needed for reporting once reporting is resumed. We recommend department management resume FFATA reporting as soon as feasible and ensure all necessary subawards are reported. We further recommend department management implement controls to ensure all subawards are appropriately tracked and reported. MANAGEMENT RESPONSE: We agree with this recommendation. On April 4, 2022, the federal government made a switch in the identifying information required for a subrecipient, changing from the previously used DUNS to a newly assigned Unique Entity Identifier (UEI). ODHS/OHA was not made aware of the upcoming federal switch until late March 2022. OHA?s Office of Contracts & Procurement (OC&P) is working directly with Program Contract Administrator?s to request the missing UEIs. As the data comes in from Program it is being validated for accuracy and updated in the appropriate systems, so when all missing UEIs from a given FAIN?s report month are collected, all NTE changes can be made immediately. OC&P is confident all FFATA reporting related to this audit will be submitted by July 31, 2023. Anticipated Completion Date: July 31, 2023 Contact: Brenda Brown, Procurement Manager
View Audit 45093
Finding 47770 (2022-101)
Significant Deficiency 2022
Labors Community Service Agency
AZ
Special Tests & Provisions Subrecipient Monitoring Significant Deficiency
Finding 2022 - 101 ? Improve Home Inspection Process (Significant Deficiency) FAL Number: 14.239 Program Title: HOME Investment Partnership Program Condition and Context: LCSA did not properly document the procedures taken to inspect the homes maintained through their HOME program. Recommendati...
Finding 2022 - 101 ? Improve Home Inspection Process (Significant Deficiency) FAL Number: 14.239 Program Title: HOME Investment Partnership Program Condition and Context: LCSA did not properly document the procedures taken to inspect the homes maintained through their HOME program. Recommendation: The auditors recommend maintaining a list or memoranda including the items inspected at each home during routine inspections for documentation purposes. Contact Name: Rebekah Friend, Executive Director Corrective Action Planned: Management is creating a procedure and form to document the tracking of homes maintained. Anticipated Completion Date: Immediately
View Audit 41448
Finding 47765 (2022-002)
Material Weakness 2022
Tattnall County Board of Education
GA
Equipment & Real Property Management Subrecipient Monitoring Reporting § 200.303 § 200.313
FA 2022-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education...
FA 2022-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: None identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. A federal inventory sheet has been developed that includes all applicable components for current assets and will be used for physical inventory purposes. Tattnall County School District has received an ESSER III- ARP-REI Technology Grant; an approved purchase in this grant is an inventory system. Systems are currently being evaluated and reviewed for purchase. It is anticipated that this system will be fully implemented during fiscal year 2024. Estimated Completion Date: June 30, 2023 for federal inventory asset sheet and June 30, 2024 for new inventory software system. Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us
View Audit 40842
Finding 47764 (2022-001)
Significant Deficiency 2022
Tattnall County Board of Education
GA
Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403 § 200.77
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of ...
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $108,220 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were allowable for the program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. The federal programs director enters and monitors all grant budgets into the consolidated application and supplies all prior approval forms for those items for which it is required. The federal programs director also approves all purchase requisitions using federal funds before items can be purchased; she also reviews and approves request for reimbursement of federal funds before those funds are drawn down. (Superintendent approves as well.) Estimated Completion Date: June 30, 2023 Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us
View Audit 40842 Questioned Costs: $1
Finding 47749 (2022-004)
Material Weakness 2022
Liberty-Perry Community School Corporation
IN
School Nutrition Programs Subrecipient Monitoring Cash Management § 200.303
FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will...
FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023
View Audit 54302
Finding 47744 (2022-004)
Material Weakness 2022
Three Rivers Community Schools
MI
Subrecipient Monitoring Material Weakness
Finding Number: 2022-004 Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds ( ESF) for minor remodeling and renovations of the school buildings. Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF for m...
Finding Number: 2022-004 Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds ( ESF) for minor remodeling and renovations of the school buildings. Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovation, or construction contracts that are over $ 2,000 and use laborers and mechanics, must meet Davis Bacon prevailing wage requirements. The School District expended approximately $ 360,000in ESSER funds that related to repairs and renovations for an indoor air purification system; however, the School District received the certified payroll reports from the contractor prior to being requested by the auditor. Planned Corrective Action: The School District will implement procedures such completing a review of contracts to make sure they include the Davis Bacon prevailing wage rate and review any certified payroll reports from the contractors. Annually for projects subject to Davis Bacon, the district will review certified payrolls of the contractors subject to the legislation. Contact person responsible for corrective action: Nikki Nash, Super intendent and Blair Brindley, Director of Business Operations. Anticipated Completion Date: 6/30/2023
View Audit 53995
Finding 47742 (2022-003)
Material Weakness 2022
Three Rivers Community Schools
MI
Internal Control / Segregation of Duties Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking
Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budge...
Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Ultimately a reconciliation was performed and approximately $ 99,000 was overcharged to Title I and subsequently reclassified as a non- grant expenditure. However, the School District requested and received reimbursement for this amount during the year- end June 30,2022. Planned Corrective Action: The School District will implement procedures to complete a review and reconciliation process to support the amount charged to Title I based on budget estimates is reasonable when compared to actual time expended on federal and state grants, specifically Title I Reconciliation will occur more than once a year to be able to align grant budgets, as needed. Contact person responsible for corrective action: Jennifer Graber, Director of Curriculum and Instruction and Blair Brindley, Director of Business Operations Anticipated Completion Date: 6/30/2023
View Audit 53995
Finding 47730 (2022-001)
Material Weakness 2022
Toutle Lake School District
WA
Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements Name, address, and telephone of District contact person: Amy Karcher, Finance Manager PO Box 8937 Vanco...
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements Name, address, and telephone of District contact person: Amy Karcher, Finance Manager PO Box 8937 Vancouver, WA 98668-8937 (360) 313-1348 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). This audit finding related to unique rules associated with one-time, pandemic-necessitated funding, so VPS is extremely unlikely to have to navigate these compliance expectations ever again. However, VPS will aspire to slow down the procurement and deployment of grant-funded resources as long as possible in the future in order to learn more of what the final audit expectations may be. Anticipated date to complete the corrective action: Undeterminable based on rarity of event
View Audit 52811 Questioned Costs: $1
Finding 47710 (2022-002)
Significant Deficiency 2022
Municipality of Naranjito
PR
Procurement, Suspension & Debarment Subrecipient Monitoring § 200.327
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF NARANJITO Corrective Action Plan For the Fiscal Year Ended June 30, 2022 _________________________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Co...
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF NARANJITO Corrective Action Plan For the Fiscal Year Ended June 30, 2022 _________________________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2021 ? June 30, 2022 Fiscal Year: 2021-2022 Principal Executive: Hon. Orlando Ortiz Chevres - Mayor Contact Person: Mrs. Belinda Alvarez, Finance Director Phone: (787) 869 - 2200 Original Finding Number: 2022-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: We are going to prepare written policies and procedures in accordance with Uniform Guidance. Implementation Date: During Fiscal Year 2022-2023. Responsible Person: Mrs. Belinda Alvarez - Finance Department Director See Corrective Action Plan for chart/table
View Audit 51135
Finding 47704 (2022-003)
Significant Deficiency 2022
Change Happens!
TX
Subrecipient Monitoring Reporting Significant Deficiency
Finding #2022-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01,...
Finding #2022-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 Condition and context: Change Happens did not file the required FFATA reporting for the 7 subawards over $30,000. Recommendation: Develop a process for FFATA reporting to ensure timely reporting for all federal programs, where applicable, and provide training to personnel regarding FFATA reporting requirements. Planned corrective action: A process for FFATA reporting will be finalized to ensure timely reporting of all federal programs. Policies and procedures will be updated to include this required reporting and the associated process. Staff training regarding FFATA reporting requirements will be provided to ensure the process is understood and properly implemented. Responsible officer: Angelica Castillo, CFO Estimated completion date: July 15, 2023
View Audit 47820
Finding 47699 (2022-001)
Material Weakness 2022
Wapato School District No. 207
WA
Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Sylvia Bazan, Business Manager 212 W. 3rd Str...
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Sylvia Bazan, Business Manager 212 W. 3rd Street Wapato, WA 98951 (509) 877-4181 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). During the COVID -19 pandemic, the District applied for ECF funding for hotspots and chrome books for our students. The Wapato School District was not a 1 to 1 District in regards to devices, but we had to pivot quickly to ensure our students had a device and connectivity. This would ensure we could provide instruction during remote learning and school closures during the pandemic. The District provided a survey to all students/parents seeking information regarding connectivity and devices. The survey results showed many of our students did not have adequate connectivity or a device to stream videos, which is needed for remote instruction. Also, the District did not receive responses from all families as they did not have connectivity to do so. The District used its library check out system to issue Chromebook and hot spots to students. The process was for students who needed a device to communicate this to their school building, then they would be directed to the library to obtain a device. The student?s requests were an unmet need. Although the student/parent did not sign a form to document unmet need, the District felt the request for a device was sufficient. As for the per location and per user limitation, the District?s library system was used to provide reports during the audit process, but it was determined the reports were not run at the time of reimbursement. The Wapato School District is a District with over 90% poverty level, the District?s priority was to ensure students were provided devices for instruction and connectivity during the pandemic. The District will strengthen its controls over documenting unmet need for students as well as maintaining reports that show per location/ per user limits at the time ECF funding is requested. Our IT department has started to implement a formal process, which includes a written application for our student/family to submit prior to receiving a device. They are also working on written instructions for the deployment of devices and documentation to be obtained. These instructions will be provided to all school buildings. Anticipated date to complete the corrective action: June 1, 2023
View Audit 49232 Questioned Costs: $1
Finding 47696 (2022-005)
Material Weakness 2022
City of Pendleton, Oregon
OR
Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles
DEPARTMENT OF TRANSPORTATION Airport Improvement Program ? CARES Act Compliance and Material Weakness ? Special Tests 2022-005 Management?s response: Economic Development & Airport Director has clearly instructed new Airport Manager on City?s purchasing procedures and stressed the importance of abi...
DEPARTMENT OF TRANSPORTATION Airport Improvement Program ? CARES Act Compliance and Material Weakness ? Special Tests 2022-005 Management?s response: Economic Development & Airport Director has clearly instructed new Airport Manager on City?s purchasing procedures and stressed the importance of abiding by them.
View Audit 49041
Finding 47695 (2022-016)
Significant Deficiency 2022
State of Hawaii, Department of Accounting and General Services
HI
Subrecipient Monitoring § 200.332
2022-016 ? Subrecipient Monitoring (Significant Deficiency) Department of Defense AL Number: 97.036 Program Title: Disaster Grants ? Public Assistance Direct Award from: Federal Emergency Management Agency (FEMA) Condition The requirement to evaluate each subrecipients? risk of noncomplianc...
2022-016 ? Subrecipient Monitoring (Significant Deficiency) Department of Defense AL Number: 97.036 Program Title: Disaster Grants ? Public Assistance Direct Award from: Federal Emergency Management Agency (FEMA) Condition The requirement to evaluate each subrecipients? risk of noncompliance was not being conducted during the audit timeframe of the awards that were audited. There was internal miscommunication as to who in the Hawaii Emergency Management Agency (HIEMA) is responsible for performing the risk assessments. Current Status of Corrective Action Plan Concur. HIEMA has implemented a Risk Assessment Policy to ensure the assessments are completed at the beginning of the grant process and conducted annually to ensure continued compliance with all grant requirements. Resilience and the Grants teams will continue to work together to ensure this process is adhered to. Person Responsible Brian Fisher ? Hawaii Emergency Management Agency ? Disaster Assistance Project Manager Lauren Mark ? Hawaii Emergency Management Agency ? Grants Program Manager Anticipated Date of Completion The Risk Assessment Policy was implemented on February 8, 2023 and outlines steps to be taken by all Grants Team members and Resilience Branch Point of Contacts to ensure compliance.
View Audit 40897
Finding 47694 (2022-013)
Material Weakness 2022
State of Hawaii, Department of Accounting and General Services
HI
Reporting Subrecipient Monitoring
2022-013 ? Reporting (Material Weakness) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition A prime recipient of a Federal award is required to fi...
2022-013 ? Reporting (Material Weakness) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition A prime recipient of a Federal award is required to file a Federal Funding Accountability and Transparency Act (FFATA) report to the FFATA Subaward Reporting System (FSRS) by a specific period for any award to a subrecipient greater than or equal to $30,000. The State awarded Governor?s Emergency Education Relief Fund (GEER) I and II funds to the Research Corporation of the University of Hawaii (RCUH). At the time of award, RCUH was improperly designated as a subrecipient rather than a grants management contractor. RCUH?s role was to disburse GEER funds in the form of innovation grants to various public/private schools and non profit organizations. Innovation grants were awarded to 31 organizations. B&F did not file FFATA reports for the recipients of the 31 innovation grants. B&F did file a FFATA report for RCUH. Subsequently, the U.S. Department of Education (US DOE) provided additional guidance to B&F and suggested that the FFATA reports be amended to remove RCUH as a subrecipient and for B&F to submit a FFATA report to FSRS for the organizations that received innovation grants. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200 for the determination of subrecipients and FFATA reporting requirements. In addition, B&F will work with U.S. DOE to take appropriate action to address the lack of FFATA reports for the recipients of GEER innovation grants. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023
View Audit 40897
Finding 47693 (2022-015)
Significant Deficiency 2022
State of Hawaii, Department of Accounting and General Services
HI
Subrecipient Monitoring
2022-015 ? Special Tests and Provisions (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition A local education agency that ...
2022-015 ? Special Tests and Provisions (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition A local education agency that receives funds under the Governor?s Emergency Education Relief (GEER I) Fund program must provide equitable services to students and teachers in private schools. During the audit, B&F was unable to locate documentation to verify that timely consultation with private school officials occurred. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel maintain evidence of compliance with all grant requirements. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023
View Audit 40897
Finding 47692 (2022-014)
Material Weakness 2022
State of Hawaii, Department of Accounting and General Services
HI
Subrecipient Monitoring § 200.332
2022-014 ? Subrecipient Monitoring (Material Weakness) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition 2 CFR Section 200.332(a) requires a pass...
2022-014 ? Subrecipient Monitoring (Material Weakness) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition 2 CFR Section 200.332(a) requires a pass-through entity to ensure that every subaward is clearly identified to the subrecipient as a subaward and provide specific Federal award information to subrecipients at the time of the subaward. 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Due to the improper determination of the Research Corporation of the University of Hawai`i as a subrecipient rather than a grants contractor, State program management did not ensure Federal award information was included in the subawards to the entities ultimately determined to be first tier subrecipients. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with all grant requirements including compliance with 2 CFR Section 200.332 (a) and (b) which requires the reporting of specific Federal award information to subrecipients and performing an evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023
View Audit 40897
Finding 47657 (2022-003)
Material Weakness 2022
Oconto County, Wisconsin
WI
Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking
The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 2023 Name of the contact per...
The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director
View Audit 51115
Finding 47645 (2022-007)
Material Weakness 2022
South Adams Schools
IN
Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303
CORRECTIVE ACTION PLAN FINDING 2022-007 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district provided documentation of the email correspondence with the design build project manager...
CORRECTIVE ACTION PLAN FINDING 2022-007 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district provided documentation of the email correspondence with the design build project manager. The project manager emailed the district once a month with two separate invoices showing what work had been completed on the project. Once the email was received we had an individual internally check the invoices line for line to confirm that all costs were included in both invoices. Verbal authorization was given to accounts payable to proceed with payment. The district did not have documentation of email verification attesting approval of the invoices. Description of Corrective Action Plan: We have spoken to PSI about a process. We have determined the following, PSI requires subcontractors to submit the certified payroll reports along with their billings. PSI accounting team collects and verifies dates of the CP reports. PSI does not fund the subcontractors? billings until receipt of reports. Once PSI had verified their process the billings will be sent to the district and approval from the Superintendent or Business Manager will be determined before bills will be submitted to the Business Office Manager for submission of payment for the School Board Approval. Anticipated Completion Date: Immediately
View Audit 48846
Finding 47623 (2022-003)
Material Weakness 2022
Shoals Community School Corporation
IN
School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303
FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Ind...
FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: For all four monthly claims selected for testing, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Tamara Florio, Director of School Nutrition, will prepare and submit the claims after they have been signed and reviewed by Kendra Wright, Treasurer. Kendra Wright, Treasurer, will also compare claims with reimbursements and will sign prepared monthly reimbursement claim reports. Responsible Party and Timeline for Completion: Tamara Florio, Director of School Nutrition, and Kendra Wright, Treasurer ? these changes will be implemented effective immediately.
View Audit 48844
Eastern Center for Arts and Technology
PA
Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.305
2022-002 HEERF Institutional Aid Portion ? Assistance Listing No. 84.425F, Grant Period May 20, 2020 through May 11, 2022; and Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ? Assistance Listing No. 84.425E, grant period April 25, 2020 through May 11, 2022 Recommendation: Easte...
2022-002 HEERF Institutional Aid Portion ? Assistance Listing No. 84.425F, Grant Period May 20, 2020 through May 11, 2022; and Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ? Assistance Listing No. 84.425E, grant period April 25, 2020 through May 11, 2022 Recommendation: Eastern Center for Arts and Technology should more closely monitor the timing of the expenditure of federal funds received. In addition, Eastern Center for Arts and Technology should return unexpended funds once the grant period has ended. Corrective Actions Plan: Moving forward, we will be creating a means of capturing federal grant costs by using funding sources that are provided through our financial software program to track and monitor federal grants. In doing this, it will allow us to account for the funds appropriately. The grant time frame for the expenditure of federal funds was extended to June 30, 2023. Due to this, we will not have to return any federal funding.
View Audit 46390
Finding 47603 (2022-003)
Significant Deficiency 2022
Morningstar Children and Family Services, Inc.
GA
Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring
Finding 2022-003 Condition: Supporting documentation was missing for 3 of 40 disbursements selected for allowable cost testing. Cause: Internal controls did not provide for supporting documentation to be adequately retained. Recommendation: Internal control procedures on recordkeeping and filing...
Finding 2022-003 Condition: Supporting documentation was missing for 3 of 40 disbursements selected for allowable cost testing. Cause: Internal controls did not provide for supporting documentation to be adequately retained. Recommendation: Internal control procedures on recordkeeping and filing should be clearly stated as part of the Organizational policy. Management Response: We concur with the finding. The receipts, with a total value less than $200 could not be located during the audit. Corrective Actions: 1. Actions have been taken to diminish the use of the company credit card for purchases. 2. Beginning March 2023, an enterprise level application was deployed to track and automate the collection of expenses and receipts for approved users. 3. The accounting department has set up additional direct bill accounts for improved ordering processes and less frequent use of credit cards and subsequent receipt retention requirements. Name of Responsible Person: Beth VanDerbeck
View Audit 41687
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