FINDING REFERENCE NUMBER 2023-056 (See Finding Reference Number 2023-025) FEDERAL PROGRAMS (ALN – 93.558) TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) (ALN – 93.560) PAYMENT TO TERRITORIES – ADULT U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS 2021G996117; 2022G996117; 2023996117 (Federal Award Years: 2021 through 2023) 2022G9922PT; 2301PRTABD (Federal Award Years: 2022 through 2023) ADMINISTRATION ADMINISTRATION FOR SOCIOECONOMIC DEVELOPMENT OF THE FAMILY (ADSEF, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT REPORTING – FINANCIAL TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA The 2 CFR 200 §200.302, Financial Management, establishes that: “(a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State's funds. All recipient and subrecipient 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 the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. See § 200.450. (b) The recipient's and subrecipient's financial management system must provide for the following (see §§ 200.334, 200.335, 200.336, and 200.337): (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. (3) Maintaining 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. (4) Effective control over and accountability for all funds, property, and assets. The recipient or subrecipient must safeguard all assets and ensure they are used solely for authorized purposes. See § 200.303. … (6) Written procedures to implement the requirements of § 200.305 and (7) Written procedures for determining the allowability of costs in accordance with subpart E and the terms and conditions of the Federal award. STATEMENT OF CONDITION As part of our audit procedures over the reporting requirement for TANF and Payment to Territories – Adult programs, we selected two reports submitted during our fiscal year. We found the following deficiencies: i. Administrative expenditures related to both programs are recorded under the same accounting account number, and the assistance listing number of TANF. That is, in PRIFAS, the administrative expenditures of both programs are not segregated by grant award and assistance listing number. ii. The ACF-196TR reports report expenditures under both programs that are not reconciled with the PRIFAS accounting system, specifically in administrative expenditures. We requested evidence of the expenditures incurred or details that were used to prepare the reports; this information was not available, and it was generated upon our request. iii. In both reports evaluated, the amounts reported on lines 2 and 3, related to the amounts that the TANF program transfers to two other federal programs, are recorded inconsistently. During the quarters from October to June, these lines report the amount of the budget that is allowed to be transferred, without validating whether the Federal programs incurred any expenditures. In the quarterly report of September, the expenditure for these lines is reported based on the amount of drawdowns incurred. This practice is inconsistent and does not reflect the actual expenditure incurred. iv. In the quarterly report of June 2023, an expenditure of $3,733,668 was reported on line 5(a). According to PRIFAS, the reported expenditure was $1,988,000. QUESTIONED COSTS Undetermined. PERSPECTIVE INFORMATION This is a systematic deficiency. Procedures and internal controls manuals should provide for and ensure the segregation of duties, and the reconciliation of financial information reported to federal agencies against the accounting records used to prepare financial statements and SEFA. In addition, the financial management system should provide to account separately the administrative expenditures incurred among all Federal programs administered. ADSEF failure to support reported amounts with verifiable documentation and the absence of independent review increases the risk of inaccurate or misstated financial data being reported to the federal awarding agency. STATEMENT OF CAUSE During our interviews and understanding of the internal controls over financial reporting, we noted that only one person prepares, submits and certifies the ACF-196TR reports. No proper segregation of duties exists, that allows for validation of all accounting data before submitting the reports. In addition, the procedures manual for preparing reports does not establish a clear process for obtaining information, validating it, recording it, preparing it, and reporting it, as well as the responsibilities and segregation of duties to ensure that the reported information is consistent with ADSEF's accounting records. PRIFAS accounting data base as configured, does not provide for the administrative expenditures incurred from the TANF and Payment to Territories – Adult program to be segregated. ADSEF lacks internal controls that allow for the timely validation and reconciliation of financial information. Furthermore, they lack a written procedures manual detailing the processes to follow in obtaining accounting data and reporting it to the federal government, ensuring that the responsibility does not fall on a single individual. POSSIBLE ASSERTED EFFECT ADSEF does not ensure that the reports are accurate and traceable to the accounting database used to prepare their financial reports to the Federal Agencies and their financial statement. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend ADSEF to establish written procedures and internal controls manuals to provide and document the segregation of duties related to the reporting compliance requirement. Additionally, work with the Puerto Rico Department of the Treasury to provide accounting records to segregate the administrative expenditures of both programs.
FINDING REFERENCE NUMBER 2023-056 (See Finding Reference Number 2023-025) FEDERAL PROGRAMS (ALN – 93.558) TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) (ALN – 93.560) PAYMENT TO TERRITORIES – ADULT U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS 2021G996117; 2022G996117; 2023996117 (Federal Award Years: 2021 through 2023) 2022G9922PT; 2301PRTABD (Federal Award Years: 2022 through 2023) ADMINISTRATION ADMINISTRATION FOR SOCIOECONOMIC DEVELOPMENT OF THE FAMILY (ADSEF, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT REPORTING – FINANCIAL TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA The 2 CFR 200 §200.302, Financial Management, establishes that: “(a) Each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State's funds. All recipient and subrecipient 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 the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. See § 200.450. (b) The recipient's and subrecipient's financial management system must provide for the following (see §§ 200.334, 200.335, 200.336, and 200.337): (1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. When a Federal agency or pass-through entity requires reporting on an accrual basis from a recipient or subrecipient that maintains its records other than on an accrual basis, the recipient or subrecipient must not be required to establish an accrual accounting system. This recipient or subrecipient may develop accrual data for its reports based on an analysis of the documentation on hand. (3) Maintaining 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. (4) Effective control over and accountability for all funds, property, and assets. The recipient or subrecipient must safeguard all assets and ensure they are used solely for authorized purposes. See § 200.303. … (6) Written procedures to implement the requirements of § 200.305 and (7) Written procedures for determining the allowability of costs in accordance with subpart E and the terms and conditions of the Federal award. STATEMENT OF CONDITION As part of our audit procedures over the reporting requirement for TANF and Payment to Territories – Adult programs, we selected two reports submitted during our fiscal year. We found the following deficiencies: i. Administrative expenditures related to both programs are recorded under the same accounting account number, and the assistance listing number of TANF. That is, in PRIFAS, the administrative expenditures of both programs are not segregated by grant award and assistance listing number. ii. The ACF-196TR reports report expenditures under both programs that are not reconciled with the PRIFAS accounting system, specifically in administrative expenditures. We requested evidence of the expenditures incurred or details that were used to prepare the reports; this information was not available, and it was generated upon our request. iii. In both reports evaluated, the amounts reported on lines 2 and 3, related to the amounts that the TANF program transfers to two other federal programs, are recorded inconsistently. During the quarters from October to June, these lines report the amount of the budget that is allowed to be transferred, without validating whether the Federal programs incurred any expenditures. In the quarterly report of September, the expenditure for these lines is reported based on the amount of drawdowns incurred. This practice is inconsistent and does not reflect the actual expenditure incurred. iv. In the quarterly report of June 2023, an expenditure of $3,733,668 was reported on line 5(a). According to PRIFAS, the reported expenditure was $1,988,000. QUESTIONED COSTS Undetermined. PERSPECTIVE INFORMATION This is a systematic deficiency. Procedures and internal controls manuals should provide for and ensure the segregation of duties, and the reconciliation of financial information reported to federal agencies against the accounting records used to prepare financial statements and SEFA. In addition, the financial management system should provide to account separately the administrative expenditures incurred among all Federal programs administered. ADSEF failure to support reported amounts with verifiable documentation and the absence of independent review increases the risk of inaccurate or misstated financial data being reported to the federal awarding agency. STATEMENT OF CAUSE During our interviews and understanding of the internal controls over financial reporting, we noted that only one person prepares, submits and certifies the ACF-196TR reports. No proper segregation of duties exists, that allows for validation of all accounting data before submitting the reports. In addition, the procedures manual for preparing reports does not establish a clear process for obtaining information, validating it, recording it, preparing it, and reporting it, as well as the responsibilities and segregation of duties to ensure that the reported information is consistent with ADSEF's accounting records. PRIFAS accounting data base as configured, does not provide for the administrative expenditures incurred from the TANF and Payment to Territories – Adult program to be segregated. ADSEF lacks internal controls that allow for the timely validation and reconciliation of financial information. Furthermore, they lack a written procedures manual detailing the processes to follow in obtaining accounting data and reporting it to the federal government, ensuring that the responsibility does not fall on a single individual. POSSIBLE ASSERTED EFFECT ADSEF does not ensure that the reports are accurate and traceable to the accounting database used to prepare their financial reports to the Federal Agencies and their financial statement. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend ADSEF to establish written procedures and internal controls manuals to provide and document the segregation of duties related to the reporting compliance requirement. Additionally, work with the Puerto Rico Department of the Treasury to provide accounting records to segregate the administrative expenditures of both programs.
2023-001 Supporting Documentation and Approval of Disbursements Federal Program - U.S. Department of the Treasury – Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal Award Number - SLFRP0136 Compliance Requirement - Allowable Costs/Cost Principles (2 CFR § 200.403 and § 200.302) Criteria - Per 2 CFR § 200.403(g), to be allowable under a federal award, costs must be adequately documented. Additionally, 2 CFR § 200.302 requires the non-Federal entity to establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Condition - During our testing of expense and disbursement transactions charged to the federal program, we identified instances where payments were made without adequate supporting documentation or evidence of appropriate review and approval. While the costs appear consistent with the purpose of the program and are considered allowable in nature, the absence of documentation limits the ability to verify the appropriateness and accuracy of the expenditures. A majority of these transactions were related to temporary housing assistance, including payments to hotels. Cause - The organization does not currently have or did not follow a formal process to ensure that all disbursements are properly documented and reviewed. Effect - Failure to maintain adequate documentation impairs the organization’s ability to demonstrate compliance with federal requirements and increases the risk of errors or inappropriate expenditures going undetected. Questioned Costs - $0. No costs are questioned at this time, as the disbursements appear consistent with program objectives. Recommendation - We recommend that the organization strengthen internal controls over the disbursement process by implementing procedures requiring all expenses to be supported by documentation such as invoices or receipts and be reviewed and approved by appropriate personnel prior to payment. This is especially important for recurring or program-critical costs such as temporary housing. Views of Responsible Officials - we agree with the finding and determined it was due to an oversight by the organization on establishing proper procedures for a new program. Verbal communications were not recorded appropriately and approvals were not signed by management.
Type of finding: Federal Award. Situation: Material weakness; Material noncompliance with federal regulations. Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing 21.027 Compliance Requirements: Activities allowed or unallowed / Allowable costs/Cost Principle Prior-Year(s) Audit Finding(s): 2022-004 Questioned Costs: $164,619 Condition: The Municipality could not provide supporting documentation for the disbursement of $164,619 of program funds. Documentation for the disbursement of $164,619 of program funds was not identified by the Municipality nor provided for our review, therefore we could not ascertain that the disbursements complied with program regulations. Context: The Municipality recognized as revenue $3,518,621 during the fiscal year ended on June 30, 2023. A total of $164,619 of program funds were disbursed without sufficient and appropriate documentation. The Municipality indicated that Revenue Replacement was their only project expenditure category on their annual March 2023 SLFRF Compliance Report. Revenue loss in and of itself is not an eligible use. Instead, recipients calculate lost revenue based on the formula provided in the Interim Final Rule and Final Rule to determine the limit for funds that can be used for the provision of government services. Entities are expected to use the direct payments to meet pandemic response needs and rebuild a strong, more equitable economy as the country recovers. Interim and final regulations state that recipients may not use funds to pay interest or principal on outstanding debt, as these expenses would not address the needs of pandemic response or its negative economic impacts. Such expenses would also not be considered provision of government services, as these financing expenses do not directly provide services or aid to citizens. The Coronavirus State and Local Fiscal Recovery Funds program is authorized by sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (Mar. 11, 2021). Recipients may use payments from the Fund to among other things, replace lost public sector revenue to provide government services. Criteria: Uniform Guidance states in 2 CFR 200.403 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. As per 2 CFR 200.302 the other non-Federal entity’s financial management system must provide for the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the Federal Award. Further, Coronavirus Local Fiscal Recovery Fund Award terms and conditions state the following regarding the maintenance of and Access to Records: 1. Recipient shall maintain records and financial documents sufficient to evidence compliance with section 603 © of the Act, Treasury’s regulations implementing that section, and guidance issued by Treasury regarding the foregoing. 2. The Treasury Office of Inspector General and the Government Accountability Office, or their authorized representatives, shall have the right of access of records (electronic or otherwise) of Recipient in order to conduct audits or other investigations. 3. Records shall be maintained by the Recipient for a period of five (5) years after all funds have been expended or returned the Treasury, whichever is later. Cause: The Municipality applied inconsistent program procedures to disbursement transactions totaling $164,619. Effect: Coronavirus Local Fiscal Recovery Fund Award terms and conditions state the following regarding Remedial Actions: In the event of recipient’s noncompliance with section 603 of the Act, other applicable laws, Treasury’s implementing regulations, guidance, or any reporting or other program requirements, Treasury may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 CFR 200.339. In case of a violation of section 603 © of the Act regarding the use of funds, previous payments shall be subject to recoupment as provided in section 603 © of the Act. Auditor’s recommendation: The Municipality must strengthen internal controls and procedures to ensure that disbursement of program funds is properly documented and allowed under program regulations. The Municipality must ensure that all documentation that serves as evidence for eligible expenses be preserved and maintained for at least five years. 2023-003, cont. Views of Responsible officials and corrective actions:
Type of finding: Federal Award. Situation: Material weakness; material noncompliance with federal regulations. Federal Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing 97.036 Compliance Requirements: Activities allowed or unallowed / Allowable costs/Cost Principle Prior-Year(s) Audit Finding(s): 2022-005, 2021-002 Questioned Costs: $14,435 Condition: The Municipality could not provide supporting documentation for the disbursement of $14,435 of program funds. Documentation for the disbursement of $14,435 of program funds was not identified by the Municipality nor provided for our review, therefore we could not ascertain that the disbursements complied with program regulations. Context: A total of $14,435 of program funds were disbursed without sufficient and appropriate documentation. In previous years, program funds were also disbursed without sufficient and appropriate documentation and were accounted for as increases in the due from other funds account. The Municipality repaid during the current year the amount of $49,839. As of June 30, 2023 the balance of the due from other funds account is $505,271. Program regulation states that costs must be directly tied to the performance of eligible work; adequately documented; reduced by all applicable credits, such as insurance proceeds and salvage values; authorized and not prohibited under Federal or State government laws or regulation; consistent with the applicant’s internal policies, regulations, and procedures that apply uniformly toboth Federal awards and other activities of the applicant; and necessary and reasonable to accomplish the work properly and efficiently. We could not ascertain that these disbursements complied with program regulations. The Public Assistance Program is authorized under the Robert T. Stafford Disaster Relief and Emergency assistance Act, as Amended (Stafford Act). Assistance is provided so that communities can quickly respond to and recover from major disasters or emergencies declared by the President. The Municipality has approved grants for the Hurricane Irma and Maria disasters declared on September 2017 (disasters 3384EMPR, 4336 DRPR and 4339 DRPR). The program approves funding for debris removal, emergency protective measures, and the restoration of disaster-damaged, publicly owned facilities. It also encourages protection of damaged facilities from future incidents by providing assistance for hazard mitigation measures. Criteria: Uniform Guidance states in 2 CFR 200.403 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. As per 2 CFR 200.302 the other non-Federal entity’s financial management system must provide for the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statues, regulations, and the terms and conditions of the Federal Award. As per 44 CFR section 206.201 and 206.203, the public assistance program provides grant funding for emergency protective measures and debris removal (Emergency Work) and for permanent restoration of damaged facilities, including cost-effective hazard mitigation to protect facilities from future damage (Permanent Work) Cause: The Municipality applied inconsistent program procedures to the three disbursement transactions totaling $189,389 Effect: Remedies for noncompliance are described in 2 CFR 200.339. Grantor may impose additional conditions as described in 2 CRF 200.208 or take one or more of the actions listed on 2 CRF 200.339 as appropriate in the circumstances. Program regulations provide for recovery of assistance and penalty provisions on 44 CFR Part 206. Auditor’s recommendation: The Municipality must strengthen internal controls and procedures to assure that disbursement of program funds are properly documented, can be directly tied to the performance of eligible work, and is allowed under program regulations. Views of Responsible officials and corrective actions:
2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College does not maintain written procedures as required by 2 CFR 200, Subparts D and E of the Uniform Guidance. Criteria: Per 2 CFR 200.302(b)(6), Financial Management, the financial management system of each non-federal entity must provide the following: Written procedures to implement the requirements of 200.305 Federal Payment. Per 2 CFR 200.302(b)(7), Financial Management, the financial management system of each nonfederal entity must provide the following: Written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles of this part and the terms and conditions of the Federal award. Cause: The College does not have written procedures for the federal program financial management requirements. Effect: Not having written procedures for the aforementioned puts the College in direct violation of Federal requirements over Federal programs under the Uniform Guidance, which could result in a loss of programs, funds and/or repayment of federal monies already awarded back to the Federal government. Questioned Costs: None Auditor recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs.
2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College does not maintain written procedures as required by 2 CFR 200, Subparts D and E of the Uniform Guidance. Criteria: Per 2 CFR 200.302(b)(6), Financial Management, the financial management system of each non-federal entity must provide the following: Written procedures to implement the requirements of 200.305 Federal Payment. Per 2 CFR 200.302(b)(7), Financial Management, the financial management system of each nonfederal entity must provide the following: Written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles of this part and the terms and conditions of the Federal award. Cause: The College does not have written procedures for the federal program financial management requirements. Effect: Not having written procedures for the aforementioned puts the College in direct violation of Federal requirements over Federal programs under the Uniform Guidance, which could result in a loss of programs, funds and/or repayment of federal monies already awarded back to the Federal government. Questioned Costs: None Auditor recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs.
2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College does not maintain written procedures as required by 2 CFR 200, Subparts D and E of the Uniform Guidance. Criteria: Per 2 CFR 200.302(b)(6), Financial Management, the financial management system of each non-federal entity must provide the following: Written procedures to implement the requirements of 200.305 Federal Payment. Per 2 CFR 200.302(b)(7), Financial Management, the financial management system of each nonfederal entity must provide the following: Written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles of this part and the terms and conditions of the Federal award. Cause: The College does not have written procedures for the federal program financial management requirements. Effect: Not having written procedures for the aforementioned puts the College in direct violation of Federal requirements over Federal programs under the Uniform Guidance, which could result in a loss of programs, funds and/or repayment of federal monies already awarded back to the Federal government. Questioned Costs: None Auditor recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs.
2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210287, P031S210288, P031C200002, P031C210215 Federal Award Year: 2023 Condition: The College does not maintain written procedures as required by 2 CFR 200, Subparts D and E of the Uniform Guidance. Criteria: Per 2 CFR 200.302(b)(6), Financial Management, the financial management system of each non-federal entity must provide the following: Written procedures to implement the requirements of 200.305 Federal Payment. Per 2 CFR 200.302(b)(7), Financial Management, the financial management system of each nonfederal entity must provide the following: Written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles of this part and the terms and conditions of the Federal award. Cause: The College does not have written procedures for the federal program financial management requirements. Effect: Not having written procedures for the aforementioned puts the College in direct violation of Federal requirements over Federal programs under the Uniform Guidance, which could result in a loss of programs, funds and/or repayment of federal monies already awarded back to the Federal government. Questioned Costs: None Auditor recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs.
Finding Number: 2023-007. Criteria or specific requirement: Adequate financial records should be maintained in accordance with 2 CFR 200.302(b)(3). Condition: The District did not maintain adequate financial records in accordance with 2 CFR 200.302(b)(3). Context: Grant expenditures were coded to the incorrect general ledger accounts. Effect: Due to grant expenditures being coded to the incorrect general ledger accounts, adequate financial records were not maintained in accordance with 2 CFR 200.302(b)(3). Cause: Grant expenditures were coded to the incorrect general ledger accounts. This resulted in inadequate financial records. Recommendation: The District should maintain adequate financial records capable of adequately identifying the source and application of grant funds in accordance wtih 2 CFR 200.302(b)(3). Management's Response: The District will work to maintain records capable of adequately identifying the source and application of grant funds.
Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E – Cost Principals. Condition: Crowhaven Apartments, Inc. did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: Crowhaven Apartments, Inc.’s written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Crowhaven Apartments, Inc. could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Crowhaven Apartments, Inc. draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and are in process of developing and implementing the appropriate policies and procedures.
Criteria: 2 CFR section 200.302(b)(3-4) states “The financial management system of each non-Federal entity must provide for the following… (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes.” Condition: During our audit we noted cases where cumulative expenditures claimed for ESSER II and ESSER III did not agree to the general ledger. Many journal entries were used to move expenditures to/from applicable grants, but they were not always properly reported on the grant expenditure reports. Context: We noted numerous immaterial discrepancies in reporting compared to actual general ledger information from the District. We consider this to be a systemic problem. None of the amounts were material to the program and extrapolation wasn’t practical because of the nature of discrepancies it was difficult to quantify them against all grant expenditures.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for costs that were already previously claimed for reimbursement in the prior year. However, the District was able to correct this error by reclassifying other eligible and allowable costs to the grant. Statement of Cause: Control procedures were not in place to reconcile the accounting records project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: The District had other allowable costs eligible to claim under the grant, therefore no questioned costs were identified. Perspective Information: This appears to be an isolated instance because all other grants received by the District appear to be properly accounted for and utilized the correct project code and source code. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require all grant reports to be reconciled to the internal accounting records prior to report submission. This reconciliation should be presented in a clear and concise manner to enable another party to review and approve before ultimately getting submitted to the grantor. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. Views of Responsible Officials: I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the District spreadsheets will include reviews by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple reviews and the addition of PO number and date of pay request, this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched to the grant funds obtained through reimbursement. The new procedure will begin immediately.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for costs that were already previously claimed for reimbursement in the prior year. However, the District was able to correct this error by reclassifying other eligible and allowable costs to the grant. Statement of Cause: Control procedures were not in place to reconcile the accounting records project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: The District had other allowable costs eligible to claim under the grant, therefore no questioned costs were identified. Perspective Information: This appears to be an isolated instance because all other grants received by the District appear to be properly accounted for and utilized the correct project code and source code. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require all grant reports to be reconciled to the internal accounting records prior to report submission. This reconciliation should be presented in a clear and concise manner to enable another party to review and approve before ultimately getting submitted to the grantor. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. Views of Responsible Officials: I am acknowledging the finding of the Federal Audit team in which an error in my spreadsheet was documented resulting in requesting a recurring expenditure on two different pay requests. The correction was made the day of the audit through coding other expenditures matching the qualifying expenditures. In the future, the District spreadsheets will include reviews by the bookkeeper and superintendent to ensure the fund pay requests are correct and not repeated. By multiple reviews and the addition of PO number and date of pay request, this will easily define a possible "doubling up" of items for a pay request. This was one finding and all other accounts reviewed were correct and accurate. Additional expenditures were corrected and easily matched to the grant funds obtained through reimbursement. The new procedure will begin immediately.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.
Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Health Center Program Cluster Assistance listing numbers: 93.224 & 93.527 Award year and number: 2023 H80CS00036 Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that organizations maintain complete and detailed records that document the source and application of federal funds. Adequate recordkeeping is essential for financial accountability and compliance with accounting standards. Condition: Transactions reviewed were lacking itemized receipts from the supporting documentation; however, it should be noted that AHCH provided credit card statements for these transactions, which allowed for some level of verification. Questioned Costs: None Context: Of a sample of 25 transactions, two were missing itemized receipts from the supporting documentation. Cause: The missing itemized receipts may be due to oversight or lack of a robust internal control process for maintaining records. Effect: The absence of itemized receipts hinders the ability to verify the legitimacy and appropriateness of these transactions, which raises concerns about the accuracy of financial reporting and compliance with accounting standards and the Uniform Guidance. Auditor’s Recommendations: Management should enforce existing internal control procedures to ensure that all transactions are adequately documented with itemized receipts. Training and guidance should also be provided to staff responsible for record-keeping to emphasize the importance of maintaining complete and detailed documentation. Management’s Response: The finance team will work to ensure that the policy regarding the use of corporate credit cards is followed. All management staff that have organizational corporate cards will be retrained on the importance of obtaining itemized receipts. In the event a receipt is lost, regardless of verifying the legitimacy of the purchase with the purchase with the direct supervisor, the finance team will ensure that the expense is not charged to any federal funding.
Finding 2023-001- Allowable Activities (Significant Deficiency) Information on the federal program: U.S. Department of Treasury, Assistance Listing No. 21.027 Coronavirus Fiscal Recovery Funds Criteria: 2 CFR 200.302 and 2 CFR 200.303 require entities to establish and maintain internal controls and financial management procedures to provide reasonable assurance the award is managed in compliance with statutes, regulations, and terms and conditions of the award and to ensure federal award expenditures adequately supported by source documentation. Condition: We tested controls over disbursements to 9 hospitals during the year. For each hospital to receive funding they were to submit a staffing spreadsheet reporting their increased staffing costs due to COVID. Of the 9 tested, 4 hospitals supporting documentation was not readily available. Additional information, therefore, had to be obtained from the hospital to support the information reported by the hospital in the staffing spreadsheet. In addition, one of the 4 tested could not provide documentation that agreed to the amounts reported on the staffing spreadsheet. Cause: Salary information obtained in support of the staffing spreadsheet included Form 941, Employees Quarterly Federal Tax Return (941). However, some 941s are combined with other hospitals or filed by agency and did not agree to amounts submitted for reimbursement. Additional general ledger information had to be requested from the hospitals during the audit to reconcile to the amounts reported in the staffing spreadsheet. Effect: Internal Controls were not properly implemented to obtain source documentation to adequately support the amounts reported by the hospitals as additional staffing costs. Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursements to hospitals to ensure the amounts reported were determined accurate and source documentation is retained to ensure compliance requirements. Views of Responsible Officials and Planned Corrective Action: See Management’s View and Corrective Action Plan included at the end of the report.
21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. Condition: City of Oregon City has not developed written procedures for determining the allowability of costs. Cause: Administration did not have written procedures for determining the allowability of costs. Effect: Unallowable costs could be charged to the program. Questioned Costs: None Perspective: Written procedures for determining the allowability of costs is integral to the proper design of internal controls. However, the results of audit procedures did not detect any costs which are not allowable charged to the program. Recommendations: Management should develop written procedures as required by 2 CFR Part 200.302(b)(7). Views of Responsible Officials: Management understands the requirement for written procedures for determining the allowability of costs. A formal policy and procedure was approved and adopted August 22, 2023. The opportunity to identify this finding arose due to new management staff and a new audit firm engaged with the June 30, 2022, audit, and we appreciate the opportunity to improve compliance.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-002 Significant Deficiency Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant payment request for reimbursements or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Views of Responsible Officials: The District will correct and resubmit previous ASBRs, and will institute proactive measures where the Superintendent, or other designated District representative, will verify that the District’s accounting software records mirror the accurate totals for expense codes, including project codes, before future reimbursement requests for federal funds are submitted. See Correction Action Plan.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-002 Significant Deficiency Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant payment request for reimbursements or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Views of Responsible Officials: The District will correct and resubmit previous ASBRs, and will institute proactive measures where the Superintendent, or other designated District representative, will verify that the District’s accounting software records mirror the accurate totals for expense codes, including project codes, before future reimbursement requests for federal funds are submitted. See Correction Action Plan.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-002 Significant Deficiency Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant payment request for reimbursements or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Views of Responsible Officials: The District will correct and resubmit previous ASBRs, and will institute proactive measures where the Superintendent, or other designated District representative, will verify that the District’s accounting software records mirror the accurate totals for expense codes, including project codes, before future reimbursement requests for federal funds are submitted. See Correction Action Plan.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-003 Material Weakness Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Additionally, the calculation for allocating expenses and the journal entries made were not approved. The District must be able to specifically identify and provide support for every Federal expenditure that is reimbursed. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. The District failed to review expenses throughout the year to ensure transactions were properly classified. Controls were not in place to properly review expense allocations or journal entries. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Controls should be implemented for adjustments that need to be made to be reviewed by a person other than the one recording the adjustment. Evidence of reconciliations and reviews should be clearly identifiable. Views of Responsible Officials: The Hannibal School District received millions of one-time federal grant monies to assist with expenditures incurred as a result of the effects of the coronavirus pandemic. Although these funds were hugely helpful, minimal guidance was available. This is not a finding that has been presented to us in the past. The school district has received federal and state grants annually that are reconciled to the appropriate project codes and this process will be diligently followed as in prior years. For example, the district was awarded the Immediate Responses Services grant in Fall 2023. The expenditure project codes for this grant have been provided by grant guidance and any and all expenditures will be coded using these expenditures codes. This should prevent any need for future journal entries moving forward. This process is an example of the systematic process that will be followed for all grants. See Corrective Action Plan.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-003 Material Weakness Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Additionally, the calculation for allocating expenses and the journal entries made were not approved. The District must be able to specifically identify and provide support for every Federal expenditure that is reimbursed. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. The District failed to review expenses throughout the year to ensure transactions were properly classified. Controls were not in place to properly review expense allocations or journal entries. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Controls should be implemented for adjustments that need to be made to be reviewed by a person other than the one recording the adjustment. Evidence of reconciliations and reviews should be clearly identifiable. Views of Responsible Officials: The Hannibal School District received millions of one-time federal grant monies to assist with expenditures incurred as a result of the effects of the coronavirus pandemic. Although these funds were hugely helpful, minimal guidance was available. This is not a finding that has been presented to us in the past. The school district has received federal and state grants annually that are reconciled to the appropriate project codes and this process will be diligently followed as in prior years. For example, the district was awarded the Immediate Responses Services grant in Fall 2023. The expenditure project codes for this grant have been provided by grant guidance and any and all expenditures will be coded using these expenditures codes. This should prevent any need for future journal entries moving forward. This process is an example of the systematic process that will be followed for all grants. See Corrective Action Plan.
Findings and Questioned Costs – Major Federal Award Programs Audit Finding 2023-003 Material Weakness Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425 Education Stabilization Fund – Elementary and Secondary Education Compliance Requirements: B. Allowable Costs and L. Reporting Criteria: In accordance with 2 CFR part 200.302, the District is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally-funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Thus, it is critical to have a process in place to regularly reconcile underlying financial records with the grant reports. This will also help ensure correct revenue is being reported and underlying costs in the financial records are supported. Statement of Condition: During the course of our audit, we noted that the District requested reimbursement for expenses that were not properly supported by the necessary project codes and source codes in the financial management system. The grant payment request for reimbursements for respective Federal grants were not reconciled to the District’s general ledger and the classification of expenditures did not agree to what was detailed on the grant payment request for reimbursements. Additionally, the calculation for allocating expenses and the journal entries made were not approved. The District must be able to specifically identify and provide support for every Federal expenditure that is reimbursed. Statement of Cause: Control procedures were not in place to reconcile the general ledger project codes to the grant payment request for reimbursement for the grant. The District failed to review expenses throughout the year to ensure transactions were properly classified. Controls were not in place to properly review expense allocations or journal entries. Statement of Effect: Without timely reconciliations and monitoring processes, grant expenditures can be omitted or overstated on submitted grant reports or other grant noncompliance can be overlooked. This could result in missed funding or noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs. Perspective Information: This appears to be a systemic problem because after reviewing other grants received by the District, the correct project codes and source codes were not being properly utilized. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require grant payment request for reimbursements and any other required reporting to be reconciled to the internal accounting records prior to report submission. The District must be able to specifically identify and provide support for every expenditure that is reimbursed. A review should be performed to ensure the expenditures are properly classified and allowable. This process should be attainable if each grant utilizes the proper project codes and sources codes as required by the grant agreements. The reconciliation should be monitored by someone not responsible for the recording and procedures should be put in place to ensure the reconciliation is being performed timely. Controls should be implemented for adjustments that need to be made to be reviewed by a person other than the one recording the adjustment. Evidence of reconciliations and reviews should be clearly identifiable. Views of Responsible Officials: The Hannibal School District received millions of one-time federal grant monies to assist with expenditures incurred as a result of the effects of the coronavirus pandemic. Although these funds were hugely helpful, minimal guidance was available. This is not a finding that has been presented to us in the past. The school district has received federal and state grants annually that are reconciled to the appropriate project codes and this process will be diligently followed as in prior years. For example, the district was awarded the Immediate Responses Services grant in Fall 2023. The expenditure project codes for this grant have been provided by grant guidance and any and all expenditures will be coded using these expenditures codes. This should prevent any need for future journal entries moving forward. This process is an example of the systematic process that will be followed for all grants. See Corrective Action Plan.
U.S. Department of Health and Human Services, California Department of Social Services Federal Financial Assistance Listing/CFDA Number 93.575 Award Year 2022/23 Child Care and Development Fund Cluster Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Criteria: Title 2 CFR Section 200.302(b)(7) of the Uniform Guidance requires all non-Federal entities establish written procedures to implement the requirements for determining the allowability of costs in accordance with Subpart E – Cost Principles and the conditions of the Federal award. Condition: The Commission has not established written procedures for determining allowability of costs in accordance with Subpart E – Cost Principles or the conditions of the Federal award. Cause: The Commission’s procedures did not ensure the required written procedures were developed and implemented in accordance with the Uniform Guidance. Effect: The Commission has not complied with Title 2 CFR Section 200.302(b)(7) regarding establishing written procedures for determining the allowability of costs. Questioned Costs: None reported. Context: The condition noted above was identified during our procedures related to allowable costs. Repeat Finding from Prior Year: Yes – 2022-001 Recommendation: We recommend the Commission establish policies and formalize written procedures related to allowable costs in accordance with Subpart E – Cost Principles. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
U.S. Department of Health and Human Services, California Department of Social Services Federal Financial Assistance Listing/CFDA Number 93.575 Award Year 2022/23 Child Care and Development Fund Cluster Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Criteria: Title 2 CFR Section 200.302(b)(7) of the Uniform Guidance requires all non-Federal entities establish written procedures to implement the requirements for determining the allowability of costs in accordance with Subpart E – Cost Principles and the conditions of the Federal award. Condition: The Commission has not established written procedures for determining allowability of costs in accordance with Subpart E – Cost Principles or the conditions of the Federal award. Cause: The Commission’s procedures did not ensure the required written procedures were developed and implemented in accordance with the Uniform Guidance. Effect: The Commission has not complied with Title 2 CFR Section 200.302(b)(7) regarding establishing written procedures for determining the allowability of costs. Questioned Costs: None reported. Context: The condition noted above was identified during our procedures related to allowable costs. Repeat Finding from Prior Year: Yes – 2022-001 Recommendation: We recommend the Commission establish policies and formalize written procedures related to allowable costs in accordance with Subpart E – Cost Principles. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, VA Supportive Services for Veteran Families – Shallow Subsidy, and VA Supportive Services for Veteran Families – Legal Services 2021-2022 and 2022-2023 Funding U.S. Department of Veteran Affairs Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $1,617 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan
2023-003 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, VA Supportive Services for Veteran Families – Shallow Subsidy, and VA Supportive Services for Veteran Families – Legal Services 2021-2022 and 2022-2023 Funding U.S. Department of Veteran Affairs Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $1,617 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan
2023-003 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, VA Supportive Services for Veteran Families – Shallow Subsidy, and VA Supportive Services for Veteran Families – Legal Services 2021-2022 and 2022-2023 Funding U.S. Department of Veteran Affairs Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $1,617 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan
2023-002 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 21.027 COVID - 19 Coronavirus State and Local Fiscal Recovery Funds 2022-2023 Funding U.S. Department of Treasury Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $2,668 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan.
2023-002 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 21.027 COVID - 19 Coronavirus State and Local Fiscal Recovery Funds 2022-2023 Funding U.S. Department of Treasury Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $2,668 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan.
2023-002 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 21.027 COVID - 19 Coronavirus State and Local Fiscal Recovery Funds 2022-2023 Funding U.S. Department of Treasury Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of these costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Condition: We noted instances of the allocation rates being used to calculate amount of payroll costs to charge to grants did not agree to the hours incurred per approved timesheets. Cause: Certain payroll allocation spreadsheets used to calculate amounts to charge grants for payroll costs were not updated to agree with the approved timesheets. Effect: The Agency requested in error reimbursement for unallowable payroll costs. Questioned Costs: $2,668 Perspective: Errors were noted during periods when the prior accounting team was in place or during transition period as the new accounting staff were being hired. Such errors resulted in certain employees’ times under / over allocated, thus reducing overall financial impact. Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan.
Federal Program: ALN 84.425 Education Stabilization Fund (ESF) Condition: The Academy does not have formally documented written controls to ensure compliance with the U.S. Office of Management and Budget’s (OMB) Uniform Administrative Requirement, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), in regard to determining allowable costs, procurement procedures, and cash management. Criteria: 2 CFR § 200.302(b) requires the Academy to have written procedures related to managing cash from federal award, including determining the allowability of costs in accordance with 2 CFR 200 Subpart E – Cost Principles. Additionally, 2 CFR § 318(a) and (c), requires the Academy to formally document procedures used for procurements made within federal programs, to demonstrate compliance with Uniform Guidance, which includes written standards of conduct that cover conflicts of interest and govern the performance of individuals engaged in procurement. Cause: The Academy’s policies and procedures have not been formally drafted and updated in written form to the extent sufficient to meet the requirements above. Effect: The failure to have written policies and procedures resulted in the Academy’s noncompliance with the requirements of the Uniform Guidance. Context: This is a general requirement that pertains to most federal grants. This was not identified via sampling procedures. Questioned Costs: None identified. Recommendation: We recommend the Academy review the Electronic Code of Federal Regulations, particularly the sections referenced above, to obtain a better understanding of the related requirements under Uniform Guidance. Based on this understanding, we recommend the Academy adopt written policies and procedures pertaining to cash management, determining the allowability of costs, and procurement procedures for all federal programs. Views of Responsible Officials and Planned Corrective Actions: Management agrees with our recommendation. See corresponding Corrective Action Plan.
Federal Program: ALN 84.425 Education Stabilization Fund (ESF) Condition: The Academy does not have formally documented written controls to ensure compliance with the U.S. Office of Management and Budget’s (OMB) Uniform Administrative Requirement, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), in regard to determining allowable costs, procurement procedures, and cash management. Criteria: 2 CFR § 200.302(b) requires the Academy to have written procedures related to managing cash from federal award, including determining the allowability of costs in accordance with 2 CFR 200 Subpart E – Cost Principles. Additionally, 2 CFR § 318(a) and (c), requires the Academy to formally document procedures used for procurements made within federal programs, to demonstrate compliance with Uniform Guidance, which includes written standards of conduct that cover conflicts of interest and govern the performance of individuals engaged in procurement. Cause: The Academy’s policies and procedures have not been formally drafted and updated in written form to the extent sufficient to meet the requirements above. Effect: The failure to have written policies and procedures resulted in the Academy’s noncompliance with the requirements of the Uniform Guidance. Context: This is a general requirement that pertains to most federal grants. This was not identified via sampling procedures. Questioned Costs: None identified. Recommendation: We recommend the Academy review the Electronic Code of Federal Regulations, particularly the sections referenced above, to obtain a better understanding of the related requirements under Uniform Guidance. Based on this understanding, we recommend the Academy adopt written policies and procedures pertaining to cash management, determining the allowability of costs, and procurement procedures for all federal programs. Views of Responsible Officials and Planned Corrective Actions: Management agrees with our recommendation. See corresponding Corrective Action Plan.
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: 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 $134,309 of expenditures at 6/30/23. 10. Questioned Costs: $134,309. 11. Context: The District claimed expenditures that did not agree with their underlying accounting records. 12. Effect: The District was not compliant with reporting requirements. Inaccurate reporting resulted in the District being reimbursed for an additional $134,309 as of 6/30/23. As a result of the overclaim, federal expenditures were reduced on the SEFA from $739,399 to $605,090. 13. Cause: Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on two function object codes by a cumulative amount of $134,309. Under 1000-400, total expenditures were $9,298 but District claimed $9,399, resulting in an overclaim of $101. Under 2530-500, total expenditures were $595,792 but District claimed $730,000, resulting in an overclaim of $134,208. 14. Recommendation: We recommend that management review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, we recommend the District to adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. 15. Management's response: The District has agreed with the findings and recommendations as presented. See Corrective Action Plan provided by the District.
U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425W, 84.425U, 84.425D Finding 2023-001 SIGNIFICANT DEFICENCY AND MATERIAL NONCOMPLIANCE Internal Controls and Report Submissions Criteria: Pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.303 “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.” Also pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.302 Financial Management (2 CFR §200.302), “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received.” Condition: When investigating the controls related to Education Stabilization Fund reporting to the State of Kanas, we became aware that the same individual compiling the information is the same submitting the reports with no secondary review. During our examination of the reports submitted for the fiscal year, the report for the quarter ending June 2023 did not back to financial records by approximately $70,441. Cause: The controls related to reporting for Education Stabilization Fund are non-existent. Effect: There is no internal control related to reporting for Education Stabilization Fund. Questioned Costs: $70,441 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding. See separate document for planned corrective actions.
2023-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Program: Department of Homeland Security Federal Emergency Management Agency Federal Assistance Listing Number: 97.024 Federal Assistance Listing Name: Emergency Food and Shelter National Board Program Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Name Award Period The United Way SE Family Center DC Phase 39 November 1, 2021 to April 30, 2023 The United Way SE Family Center DC ARPAR November 1, 2021 to April 30, 2023 The United Way Mont. Co Family Center Phase 39 November 1, 2021 to April 30, 2023 The United Way Mont. Co Family Center ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners PG Co Phase 39 November 1, 2021 to April 30, 2023 The United Way Parish Partners PG Co ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners Calvert Co ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners Charles Co ARPAR November 1, 2021 to April 30, 2023 The United Way Angel’s Watch Charles Co ARPAR November 1, 2021 to April 30, 2023 The United Way St. Josephine’s Shelter DC ARPAR November 1, 2021 to April 30, 2023 The United Way Adam’s Place Shelter DC ARPAR November 1, 2021 to April 30, 2023 The United Way SMFB ARPAR November 1, 2021 to April 30, 2023 The United Way SCC Food Pantry Phase 39 November 1, 2021 to April 30, 2023 The United Way SCC Food Pantry ARPAR November 1, 2021 to April 30, 2023 The United Way Phase HR22 April 13, 2022 to July 7, 2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a 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. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
2023-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Program: Department of Homeland Security Federal Emergency Management Agency Federal Assistance Listing Number: 97.024 Federal Assistance Listing Name: Emergency Food and Shelter National Board Program Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Name Award Period The United Way SE Family Center DC Phase 39 November 1, 2021 to April 30, 2023 The United Way SE Family Center DC ARPAR November 1, 2021 to April 30, 2023 The United Way Mont. Co Family Center Phase 39 November 1, 2021 to April 30, 2023 The United Way Mont. Co Family Center ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners PG Co Phase 39 November 1, 2021 to April 30, 2023 The United Way Parish Partners PG Co ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners Calvert Co ARPAR November 1, 2021 to April 30, 2023 The United Way Parish Partners Charles Co ARPAR November 1, 2021 to April 30, 2023 The United Way Angel’s Watch Charles Co ARPAR November 1, 2021 to April 30, 2023 The United Way St. Josephine’s Shelter DC ARPAR November 1, 2021 to April 30, 2023 The United Way Adam’s Place Shelter DC ARPAR November 1, 2021 to April 30, 2023 The United Way SMFB ARPAR November 1, 2021 to April 30, 2023 The United Way SCC Food Pantry Phase 39 November 1, 2021 to April 30, 2023 The United Way SCC Food Pantry ARPAR November 1, 2021 to April 30, 2023 The United Way Phase HR22 April 13, 2022 to July 7, 2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a 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. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
Finding Number: 2023-001 Federal Program: COVID-19 ARP Elementary and Secondary School Emergency Relief Federal Award Identification Number and Year: N/A, 2023 Assistance Listing Number (ALN): 84.425U Federal Awarding Agency: U.S. Department of Education Compliance Requirement: Reporting – Final Expenditure Report Pass-through Entity: Ohio Department of Education Repeat Finding: No Significant Deficiency and Noncompliance – Reporting of Final Expenditure Report Criteria: 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.302(b)(2) which states, in part, the financial management system of each non-Federal entity must provide for the 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. 2 C.F.R. § 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 C.F.R. § 200.344(a) states, in part, a subrecipient must submit to the pass-through entity, no later than 90 calendar days (or an earlier date as agreed upon by the pass-through entity and subrecipient) after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award. Ohio Department of Education Grants Manual requires a final expenditure report (FER) to be submitted to show how grant funds were expended during the grant period for each project immediately after all financial obligations have been liquidated. FERs are to be submitted by September 30. Condition: The Academy did not start and submit the FER until October 3, 2022, three days after the deadline of September 30, 2022. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the FER via CCIP and noted the Academy did not start and submit the FER until October 3, 2022, which was three days after the deadline of September 30, 2022. Cause and Effect: The Academy did not have procedures in place to review and submit the Final Expenditure Report timely. As a result, the Academy filed the Final Expenditure Report after the required due date. Recommendation: We recommend that the Academy implement a process to ensure that the Final Expenditure Report is filed by the required due date. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
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 accounting records must be adequately documented and consistent with the terms and conditions of the grant. Condition: 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 $516 of expenditures at 6/30/23. Questioned Costs: $516. Context: The District claimed expenditures on their 6/30/23 expenditure report but should have been reported as OS Obligations at 6/30/23 and claimed as allowable expenses at 8/31/23. (1000-100 $480; 1000-200 $36). Effect: Upon review of the general ledger at 6/30/23 and quarterly expenditure report at 6/30/23, it was determined that the District claimed $480 under 1000-100 and $36 under 1000-200 that were expenditures paid in July 2023 and allowable on the 8/31/23 report but not the 6/30/23 and they should have been reported as OS Obligations at 6/30/23. After reviewing the 8/31/23 general ledger, these expenditures were considered allowable. 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. Recommendation: We recommend that management review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, we recommend the District to adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. Management's response: The District has agreed with the findings and recommendations as presented. See Corrective Action Plan provided by the School District.
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. Condition: 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 $4,000 of expenditures at 6/30/23. Questioned Costs: $4,000. Context: The Districts expenditures for 2210-300 at 6/30/23 were overclaimed by $4,000 due to a journal entry being made after expenditure report was submitted. Effect: The District has been in contact with ISBE and was approved to roll over the $4,000 as a prepayment to FY24 grant. 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. Recommendation: We recommend that management review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, we recommend the District to adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. Management's response: The District has agreed with the findings and recommendations as presented. See Corrective Action Plan provided by the School District.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger. Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions. Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity. Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger. Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions. Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity. Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger. Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions. Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity. Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger. Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions. Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity. Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.