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*In a sample of seventeen (17) transactions, one (1) instane was noted where the requested drawdown amount exceeded the actual expenditure paid by the County.
*In a sample of seventeen (17) transactions, one (1) instane was noted where the requested drawdown amount exceeded the actual expenditure paid by the County.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which the drawdown was not submitted on a timely basis following the incurrence of eligible expenditures.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which the drawdown was not submitted on a timely basis following the incurrence of eligible expenditures.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which the program funds were drawn in advance of making actual payments of eligible expenditues.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which the program funds were drawn in advance of making actual payments of eligible expenditues.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which amounts approved and expended related to eligible project activities that were not drawn from the IDIS system.
*In a sample of seventeen (17) transactions, we noted one (1) instance in which amounts approved and expended related to eligible project activities that were not drawn from the IDIS system.
According to HUD'[s specific drawdown rules, CDBG program funds must be drawn only for actual, eligible expenditures, and drawdowns should be timely and not made in advance of need. Additionally, all drawdowns must be properly recodrded in the IDIS system to ensure accurate tracking and reporting of...
According to HUD'[s specific drawdown rules, CDBG program funds must be drawn only for actual, eligible expenditures, and drawdowns should be timely and not made in advance of need. Additionally, all drawdowns must be properly recodrded in the IDIS system to ensure accurate tracking and reporting of program activities.
Questioned Cost:
Questioned Cost:
Hud or Grantee Administration can block drawdowns due to non-compliance.
Hud or Grantee Administration can block drawdowns due to non-compliance.
Management failed to follow proper procedures and monitoring to ensure timely and accurate drawdowns from the Integrated Disbursement and Information System (IDIS).
Management failed to follow proper procedures and monitoring to ensure timely and accurate drawdowns from the Integrated Disbursement and Information System (IDIS).
Identification of Repeat Finding:
Identification of Repeat Finding:
We recomment that management strengthen internal controls to ensure compliance with HUD case management requirements. Drawdowns should be requested only for actual, eligible expenditures submitted in a timely manner after costs are incurred, and not made in advance of need. Procedures should be impl...
We recomment that management strengthen internal controls to ensure compliance with HUD case management requirements. Drawdowns should be requested only for actual, eligible expenditures submitted in a timely manner after costs are incurred, and not made in advance of need. Procedures should be implemented to ensure alliligible expenditures are promptly drawn from the IDIS system. Any funds drawn in error or prematurely should be returned promptly to HUD or the grantee to avoid noncompliance.
Explanation & Corrective Action:
Explanation & Corrective Action:
The Division has added another member to the financial team, and will revise the review of the transactions between MSI, IDIS and the Financial Summary tio ensure all drawdowns are done timely and correct.
The Division has added another member to the financial team, and will revise the review of the transactions between MSI, IDIS and the Financial Summary tio ensure all drawdowns are done timely and correct.
Implementation Date & Explanation:
Implementation Date & Explanation:
The additional review of trqansactions has been imp0lemented as of this date.
The additional review of trqansactions has been imp0lemented as of this date.
2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michig...
2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michigan Strategic Fund. Auditor Description of Condition and Effect. Although we were able to review the quarterly reporting due during the fiscal year, we initially noted that the reports quarterly totals did not add up to the year-to-date totals, and total cost for the year reported, as well as quarterly totals, did not agree to the general ledger or the Schedule of Expenditures of Federal Awards. Management was able to subsequently correct these errors. Additionally, it was noted that there was no formal review and approval process over the completion and submission of the grant reports. As a result of this condition, the Organization reported inaccurate amounts to the grant pass-through agency. Auditor Recommendation. We recommend that the Organization base all grant financial reporting on general ledger detail of costs and that the reporting be reconciled to the Schedule of Expenditures of Federal Awards at year-end. In addition, all reports should be reviewed and approved by appropriate personnel prior to submission. Corrective Action. LEAP will be following the recommendation of basing all grant financial reporting on general ledger detail of costs and being more diligent in reconciling that ledger to the Schedule of Expenditures of Federal Awards at year-end. Further all reports moving forward will be reviewed and approved by CFO and COO in addition to the department head who is compiling with their team. LEAP’s modifications to its Grants Management SOP in 2025 are designed to also cover grant reporting process per Uniform Guidance requirements. This grant reporting issue too will be covered in the content of LEAP’s training for all management team members set to occur in August. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
2024-002 – Documentation of Controls over Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment, Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery...
2024-002 – Documentation of Controls over Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment, Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Description of Condition and Effect. During our testing of suspension and debarment for three vendors and six subrecipients, it was determined that the Organization did not verify that vendors or subrecipients were not suspended, debarred or otherwise excluded when the Organization contracted with them to provide goods or services for five of the nine vendors and subrecipients. The searches at www.sam.gov were done in early 2025 by management, which was well after the date of the applicable contractual agreement and expenditure activity. The failure to monitor suspension and debarment could cause funds to be disbursed to vendors or subrecipients who are not eligible to have goods and services purchased with federal monies. Auditor Recommendation. We recommend that the Organization retain documentation of their procurement process including checking vendors for potential exclusions from federal award work. We further recommend that these checks be done prior to entering into a contractual agreement. Corrective Action. LEAP will be following the recommendation of retaining all documentation of our procurement process including the checking of vendors both at state and federal levels for any potential exclusions from federal award work, and ensuring these checks be done prior to contract execution. LEAP will be substantially modifying its procurement policy that is part of its Grants Management SOP in order to more explicitly detail expectations and procedural steps to meet the requirements of Uniform Guidance with regards to sequence of events leading up to contract execution, including the state and federal checks for exclusion. Further, LEAP’s leadership will be holding a module within the aforementioned internal training for all management team members to walk through a new check list tool that aligns with policy and Uniform Guidance, and case study exercise will also hit on this topic to ensure learning occurs around the internal controls improvements made with policy revamp. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
2024-001 – Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance/Material Weakness in Internal Control over Compliance (Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Descr...
2024-001 – Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance/Material Weakness in Internal Control over Compliance (Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Description of Condition and Effect. Six subrecipients were selected for testing during the audit procedures. There was no subrecipient agreement noted for one of the subrecipients selected, therefore the required federal award information was not properly communicated. Additionally, no risk assessment was performed, nor was a monitoring plan within documentation of monitoring activities noted for this subrecipient. For the remaining five subrecipients selected for testing, the required federal award information was not properly communicated within the agreements. Lastly, the Organization does not have a procedure requiring the review of subrecipient audits. As a result of this condition, the Organization did not fully comply with the requirements of the Uniform Guidance. Auditor Recommendation. We recommend that management become familiar with the subrecipient monitoring requirements and draft a policy and procedures that provide reasonable assurance that future subrecipient arrangements will be in compliance with the Uniform Guidance. Corrective Action. In an effort for LEAP to become more familiar with the subrecipient monitoring requirements and drafting policy and procedures that provide assurance that future subrecipient arrangements will be in full compliance with the Uniform Guidance federal regulations, LEAP will be modifying its Grants Management SOP to more explicitly detail expectations and procedural steps to meet the requirements of Uniform Guidance. Further, LEAP’s leadership will be holding an internal training for all management team members to discuss this revamped set of policies, go through case study exercises and question and answer session to make sure that all those managing grants or the employees that manage grants have a full understanding of what is expected of them, and their role in various management and oversight processes for the organization. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement po...
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely ...
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely with project partners of federal grants to establish reporting deadlines and monitor individual reporting requirements throughout the year. This will be in tandem with establishing effective internal controls as per UGG 2 CFR 200.303. The Foundation will take steps to ensure that all required reports are submitted in a timely manner and all relevant documentation and evidence of reports’ submissions are retained in an effective manner. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and the process for internal monitoring documentation to be established by December 31, 2025.
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