Criteria or Specific Requirement: In accordance with 2 CFR 200.302(b)(1) and (b)(3), non-federal entities must maintain effective control over, and accountability for, all funds, property, and other assets. Financial management systems must allow for the identification, in their accounts, of all federal awards received and expended, and must ensure that funds are used in accordance with federal award agreements. In addition, state grant agreements typically require the separate tracking of expenditures by funding source. Condition and Context: During procedures performed over the Schedule of Expenditures of Federal Awards, it was noted that Solvista Health did not separately track expenditures, and related revenues from state and federal programs/sources for the Mental Health Block Grant. All transactions were recorded within a single classification of accounts without designation of funding or expenditure source, resulting in the commingling of revenues and expenditures. Questioned Costs: N/A Cause: Solvista Health did not implement internal control procedures to separately identify and record state and federal expenditures related to the Mental Health Block Grant. Effect: Because state and federal funds were commingled, Solvista Health could not identify federal awards received and expended under this federal program as compared to state awards received and expended. In addition, this could cause Solvista Health compliance issues with the specific allowable cost principles and reporting requirements of each funding source. This increases the risk of unallowable expenditures and may result in questioned costs or repayment obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health implement internal control procedures to establish separate accounts, classification, use of cost centers or project codes to clearly distinguish expenditures by funding source, as well as revenues received.
Criteria or Specific Requirement: In accordance with 2 CFR 200.302, non-federal entities must maintain financial systems that provide for the identification, of all federal awards received and expended, including revenues and expenditures tracked separately by federal program. Additionally, 2 CFR 200.430(i) requires that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed and must be supported by a system of internal control. Condition and Context: During the audit, it was noted that Solvista Health did not ensure that an eligible employee’s time was properly coded to the federal grant. Furthermore, the organization did not separately track grant revenues and expenditures from its general operating funds, making it difficult to clearly identify program-specific activity related to the federal award. Questioned Costs: N/A Cause: Solvista Health did not implement sufficient internal control procedures to ensure that employee timecards were accurately coded to the appropriate grant, nor to ensure that grant revenues and expenditures were tracked separately from general operating funds in accordance with grant and federal requirements. Effect: Failure to properly code eligible employee time to the appropriate grant and to separately track grant revenues and expenditures increases the risk of unallowable activities and possible questioned costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Solvista Health implement internal controls over tracking of expenditures related to federal award grants and the related reimbursed cost to ensure compliance with federal requirements.
Criteria or Specific Requirement: In accordance with 2 CFR 200.302(b)(4) and 2 CFR 200.329(a), nonfederal entities must establish internal controls to ensure accountability over federal funds and must monitor grant activities to ensure compliance with applicable requirements and achievement of performance goals. These responsibilities include assigning oversight roles and implementing processes to track both financial and programmatic aspects of federal awards. Condition and Context: During the audit, it was noted that Solvista Health did not have clearly defined roles and responsibilities for monitoring grant activities. It was difficult to determine who within the organization was responsible for overseeing compliance with grant requirements, tracking grant performance, and ensuring proper financial management of the grant funds. When asked, management was unable to identify designated individuals or a department currently accountable for these duties. Questioned Costs: N/A Cause: Solvista Health does not have an established formal grant management structure or assigned responsibility for grant oversight. Effect: Lack of properly designed and implemented internal controls, including policies and procedures relating to accountability and oversight of federal programs, may result in noncompliance with federal grant requirements under 2 CFR § 200.329 (monitoring and reporting program performance) and § 200.302 (financial management). Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments. This will help ensure that Solvista Health is in compliance with federal regulations related to the monitoring and oversight of grant activities.
Criteria or Specific Requirement: In accordance with 2 CFR 200.302(b)(4) and 2 CFR 200.329(a), nonfederal entities must establish internal controls to ensure accountability over federal funds and must monitor grant activities to ensure compliance with applicable requirements and achievement of performance goals. These responsibilities include assigning oversight roles and implementing processes to track both financial and programmatic aspects of federal awards. Condition and Context: During the audit, it was noted that Solvista Health did not have clearly defined roles and responsibilities for monitoring grant activities. It was difficult to determine who within the organization was responsible for overseeing compliance with grant requirements, tracking grant performance, and ensuring proper financial management of the grant funds. When asked, management was unable to identify designated individuals or a department currently accountable for these duties. Questioned Costs: N/A Cause: Solvista Health does not have an established formal grant management structure or assigned responsibility for grant oversight. Effect: Lack of properly designed and implemented internal controls, including policies and procedures relating to accountability and oversight of federal programs, may result in noncompliance with federal grant requirements under 2 CFR § 200.329 (monitoring and reporting program performance) and § 200.302 (financial management). Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments. This will help ensure that Solvista Health is in compliance with federal regulations related to the monitoring and oversight of grant activities.
Criteria or Specific Requirement: In accordance with 2 CFR 200.302(b)(4) and 2 CFR 200.329(a), nonfederal entities must establish internal controls to ensure accountability over federal funds and must monitor grant activities to ensure compliance with applicable requirements and achievement of performance goals. These responsibilities include assigning oversight roles and implementing processes to track both financial and programmatic aspects of federal awards. Condition and Context: During the audit, it was noted that Solvista Health did not have clearly defined roles and responsibilities for monitoring grant activities. It was difficult to determine who within the organization was responsible for overseeing compliance with grant requirements, tracking grant performance, and ensuring proper financial management of the grant funds. When asked, management was unable to identify designated individuals or a department currently accountable for these duties. Questioned Costs: N/A Cause: Solvista Health does not have an established formal grant management structure or assigned responsibility for grant oversight. Effect: Lack of properly designed and implemented internal controls, including policies and procedures relating to accountability and oversight of federal programs, may result in noncompliance with federal grant requirements under 2 CFR § 200.329 (monitoring and reporting program performance) and § 200.302 (financial management). Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments. This will help ensure that Solvista Health is in compliance with federal regulations related to the monitoring and oversight of grant activities.
Criteria or Specific Requirement: In accordance with 2 CFR 200.302(b)(4) and 2 CFR 200.329(a), nonfederal entities must establish internal controls to ensure accountability over federal funds and must monitor grant activities to ensure compliance with applicable requirements and achievement of performance goals. These responsibilities include assigning oversight roles and implementing processes to track both financial and programmatic aspects of federal awards. Condition and Context: During the audit, it was noted that Solvista Health did not have clearly defined roles and responsibilities for monitoring grant activities. It was difficult to determine who within the organization was responsible for overseeing compliance with grant requirements, tracking grant performance, and ensuring proper financial management of the grant funds. When asked, management was unable to identify designated individuals or a department currently accountable for these duties. Questioned Costs: N/A Cause: Solvista Health does not have an established formal grant management structure or assigned responsibility for grant oversight. Effect: Lack of properly designed and implemented internal controls, including policies and procedures relating to accountability and oversight of federal programs, may result in noncompliance with federal grant requirements under 2 CFR § 200.329 (monitoring and reporting program performance) and § 200.302 (financial management). Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments. This will help ensure that Solvista Health is in compliance with federal regulations related to the monitoring and oversight of grant activities.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: Title 2 of the Code of Federal Regulations (CFR) 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) specifies that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During the audit, it was noted that Solvista Health does not reconcile federal awards with the expenditures used and revenue earned. Additionally, Solvista Health did not prepare an accurate SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures and related revenue, along with the absence of an accurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and non-compliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: 2 CFR 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) mandates that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During our audit procedures performed over the current year SEFA, it was noted that Solvista Health improperly excluded expenditures for two federal awards from its June 30, 2023 SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures, along with an incomplete and inaccurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and noncompliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Additionally, the omission of federal awards from the June 30, 2023 SEFA resulted in noncompliance with federal reporting requirements and inaccurate representation of Solvista Health’s federal award activity. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
Criteria or Specific Requirement: 2 CFR 200.302(b)(4) requires non-federal entities to maintain effective internal control over federal programs. Specifically, the organization must reconcile its federal awards with expenditures incurred and revenue received. Additionally, 2 CFR Part 200.510(b)(1-6) mandates that a Schedule of Expenditures of Federal Awards (SEFA) be prepared for each fiscal year in accordance with the applicable federal regulations. The SEFA must include, at a minimum, total federal awards expended for each individual federal program and must accurately report all federal expenditures received and expended during the fiscal year. Condition and Context: During our audit procedures performed over the current year SEFA, it was noted that Solvista Health improperly excluded expenditures for two federal awards from its June 30, 2023 SEFA. Questioned Costs: N/A Cause: Solvista Health’s accounting and internal control systems were not designed and implemented to ensure reconciliation of federal awards with expenditures and revenue, and the preparation of an accurate SEFA. Effect: Failure to reconcile federal awards with expenditures, along with an incomplete and inaccurate SEFA, could lead to incorrect reporting of federal funds, misstatement of financial information, and noncompliance with federal requirements. This represents a potential risk for improper use of federal funds and an inability to meet compliance and reporting obligations. Additionally, the omission of federal awards from the June 30, 2023 SEFA resulted in noncompliance with federal reporting requirements and inaccurate representation of Solvista Health’s federal award activity. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend Solvista Health design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. Additionally, management should prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Additionally, we recommend that Solvista Health train appropriate personnel on the requirements related to federal award reconciliations and SEFA preparation to mitigate the risk of noncompliance in the future.
8. Criteria or specific requirement (including statutory, regulatory, or other citation): The compliance requirements for "L. Reporting", requires the District to maintain accurate accounting records for grant expenditures. In addition, per subpart D (Post Federal Award Requirements), § 200.302, the underlying accounts records must be adequately documented and consistent with the terms and conditions of the grant. '9. Condition: The District claimed expenditures that did not agree with their underlying accounting records. '10. Questioned Costs: 6362. '11. Context: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $6,362 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on one function object code by a cumulative amount of $6,362. under 2550-300, total expenditures were $4,573 but District claimed $10,935, resulting in an overclaim of $6,362. '12. Effect: The District was not compliant with reporting requirements. Inaccurate reporting resulted in the District being reimbursed for an additional $6,362 as of 6/30/24. 13. Cause: Policies and procedures are in place that provide reasonable assurance that reports of federal awards submitted to ISBE are supported by the underlying accounting records and are fairly presented in accordance with program requirements. These policies and procedures were not followed when the expenditure report was prepared and filed. 14. Recommendation: We recommend the District periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. 15. Management's response: The District has agreed with the findings and recommendations as presented. The District will review the itemized budget and ensure claimed expenditures fall within the grant. See Corrective Action Plan provided by the District.
8. Criteria or specific requirement (including statutory, regulatory, or other citation): The compliance requirements for "L. Reporting", requires the District to maintain accurate accounting records for grant expenditures. In addition, per subpart D (Post Federal Award Requirements), § 200.302, the underlying accounts records must be adequately documented and consistent with the terms and conditions of the grant. '9. Condition: The District claimed expenditures that did not agree with their underlying accounting records. '10. Questioned Costs: 110867. '11. Context: During compliance testing of the District’s accounting records in comparison to the expenditure reports filed with the Illinois State Board of Education, it was noted that the District overclaimed a total of $110,867 in expenditures as of June 30, 2024. The following discrepancies were identified: Function 1000-300: The District claimed $50,148 on the quarterly report filed as of 6/30/24. This amount could not be traced to the accounting records as of that date, resulting in an overclaim of $50,148. Function 1000-200: The District claimed $107,470 on the final report filed 9/30/24. Supporting expenditures could only be provided for $67,752, resulting in an overclaim of $39,718. Function 2130-100: The District claimed $10,440 on the final report filed 9/30/24. Supporting expenditures could only be provided for $10,200, resulting in an overclaim of $240. Function 2130-200: The District claimed $1,054 on the final report filed 9/30/24. Supporting expenditures could only be provided for $709, resulting in an overclaim of $345. Function 2400-100: The District claimed $44,160 on the final report filed 9/30/24. Supporting expenditures could only be provided for $37,960, resulting in an overclaim of $6,200. Function 2660-300: The District claimed $1,711,854 on the final report filed 9/30/24 for expenditures as of 6/30/24. Supporting expenditures could only be provided for $1,697,638, resulting in an overclaim of $14,216. '12. Effect: The District was not compliant with reporting requirements. Inaccurate reporting resulted in the District being reimbursed for an additional $110,867 as of 6/30/24. 13. Cause: Policies and procedures are in place that provide reasonable assurance that reports of federal awards submitted to ISBE are supported by the underlying accounting records and are fairly presented in accordance with program requirements. These policies and procedures were not followed when the expenditure report was prepared and filed. 14. Recommendation: We recommend the District periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. 15. Management's response: The District has agreed with the findings and recommendations as presented. The District will review the itemized budget and ensure claimed expenditures fall within the grant. See Corrective Action Plan provided by the District.
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank accounts and certain records and subsidiary ledgers designated for managing Community Development Block Grant / Disaster Recovery (CDBG-DR) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $850,079 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CDBG-DR program. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403 states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank accounts and certain records and subsidiary ledgers designated for managing Community Development Block Grant / Disaster Recovery (CDBG-DR) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $850,079 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CDBG-DR program. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403 states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $768,525 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CSLFRF programs. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect -These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs – None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $768,525 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CSLFRF programs. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect -These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs – None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Disaster Grants - Public Assistance (Presidentially Declared Disasters) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $4,115,693 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the grants. Criteria - The state is required to make an accounting of eligible costs. Similarly, the subrecipient must make an accounting to the state. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project in in compliance with the provisions of the State Agreement, all grants conditions were met, and the provisions for that project were made in accordance with the applicable payment provisions. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Disaster Grants - Public Assistance (Presidentially Declared Disasters) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $4,115,693 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the grants. Criteria - The state is required to make an accounting of eligible costs. Similarly, the subrecipient must make an accounting to the state. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project in in compliance with the provisions of the State Agreement, all grants conditions were met, and the provisions for that project were made in accordance with the applicable payment provisions. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the non-Federal entity’s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Information on the Federal Program: Assistance Listing Number 10.568—Food Distribution Cluster; Emergency Food Assistance Program (Food Commodities). Pass-Through Entity: Los Angeles Regional Foodbank. Compliance Requirements: Special Test and Provision. Type of Finding: Material Noncompliance. Criteria: The Compliance Supplement for the Food Distribution Cluster requires recipient organizations to maintain accurate, timely records of USDA Foods activity, including receipts, distributions (usage), and losses. Records must reflect correct quantities, proper periods, and supporting documentation for federal commodities. Additionally, Uniform Guidance 2 CFR § 200.302 mandates that non-federal entities maintain complete and accurate financial and programmatic records to ensure accountability for federal funds and assets. Condition: During our testing, we found that NVCS recorded all TEFAP distributions as a single year-end transaction instead of recording distributions as they occurred. Consequently, detailed, contemporaneous records of usage or distributions were not available, preventing verification of the accuracy, timing, and proper support of federal food distributions during the audit period. Cause: NVCS misunderstood the requirement to record USDA Foods usage and distributions throughout the year, believing a year-end summary was sufficient. Furthermore, NVCS lacked written procedures and internal controls to ensure timely and compliant documentation of commodity distributions. Effect or Potential Effect: Without detailed records of distributions throughout the year, NVCS cannot demonstrate compliance with federal requirements. This increases the risk of incorrect quantities, misreporting periods, or distributions to ineligible recipients. It may also result in questioned costs or affect NVCS’s eligibility to continue administering the program. Questioned Costs: None Context: NVCS recorded only one summary distribution transaction for the year ended June 30, 2024, representing 100% of USDA Foods activity. No detailed records were maintained, preventing sample testing and indicating a systemic control deficiency. Repeat Finding: No — This is NVCS's first Single Audit. Recommendation: We recommend NVCS establish procedures to record USDA Foods distributions at the time they occur, documenting quantities, dates, recipient agencies (if applicable), and supporting evidence. Staff should be trained on proper recordkeeping requirements, and management should implement periodic reviews to ensure accuracy and timeliness. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and will revise procedures to ensure detailed, timely recording of USDA Foods distributions. Staff will receive training on documentation requirements, and management will implement periodic compliance reviews. These corrective actions are expected to be completed by March 1, 2025.
Reference Number 2024-002 Federal Program: 21.027 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of Treasury Pass-Through Entity State of California Evaluation of Finding Significant Deficiency Compliance Area L – Reporting Condition During the allowable cost testing for the 21.027 Coronavirus State and Local Fiscal Recovery Funds program, it was found that an expenditure of $945,041 was recorded in the wrong period. The invoice indicated that the services were rendered as of June 30, 2023, but the expenditure was recorded as July 1, 2023 instead. This misstatement impacts the accuracy of financial reporting and grant compliance. Criteria According to 2 CFR 200.302(b)(3) and 2 CFR 200.303, entities receiving federal funds must maintain effective internal controls over financial reporting to ensure accurate and timely recognition of expenditures in the appropriate period. Cause of Condition The City's internal controls over financial reporting and expenditure recognition were not effectively designed or implemented, leading to recurring errors in the timing of recorded expenditures. Effect or Potential Effect of Condition Improper recording of expenditures can lead to misstatements in financial reports, noncompliance with federal grant requirements, and potential audit findings. Continued recurrence of this issue may impact the entity’s ability to demonstrate sound financial management practices. Recommendation We recommend that management continue to strengthen internal controls over expenditure recognition by implementing enhanced review procedures and periodic reconciliations to ensure expenditures are recorded in the appropriate period. Client Response The City agrees with the recommendation and has implemented new procedures and review processes to ensure expenditures for federal programs are recognized in the appropriate fiscal year's Schedule of Expenditures of Federal Awards (SEFA).
Finding 2024-012 - Material Weakness - Maintenance of Effort Federal Assistance Listing Number: 84.010 and 84.367 Federal Program Name: Title I Grants to Local Educational Agencies and Supporting Effective Instruction State Grants Federal Agency Name: U.S. Department of Education Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TI-A-141, 2024-403619-DPI-TID-144, 2024-403619-DPI-CSI-148 and 2024-403619-DPI-TIIA-365 Criteria: In accordance with 2 CFR 200.303(a), 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. In accordance with 2 CFR 200.302(a), the non-Federal entity's financial management systems must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Condition/Context: The Maintenance of Effort (MOE) calculation is calculated annually by the Wisconsin Department of Public Instruction (WI DPI) based on the information submitted in the PI-1505 report. There was a $16,977,949 variance between what was reported in the PI-1505 and the District's accounting records for the revenue source code 751. Due to this variance, we recalculated the MOE based on the District's accounting records. The MOE on a per pupil basis would have still been met. Cause: There was turnover related to those previously responsible for preparing the PI-1505 report. The cross-walk between the accounting records and the PI-1505 submission could not be located. Effect or Potential Effect: The PI-1505 report was not fully supported by the District's accounting records for one of the line items used in the calculation of MOE. Questioned Costs: None noted. Recommendations: We recommend the District establish written policies and procedures related to the preparation and submission of the PI-1505 report. The report should be fully supported by the accounting records and any cross-walk documentation should be maintained by the District. Views of Responsible Official: Management concurs with the finding.