2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2023-002 - Internal Control over Compliance and Compliance with Reporting Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Numbers: 93.650 Accountable Health Communities 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 Temporary Assistance for Needy Families 93.667 Social Services Block Grant 93.738 Racial & Ethnic Approaches to Community Health; Program Solely Funded by Public Prevention Health Funds 93.044 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers 93.052 National Family Caregiver Support 93.268 Immunization Cooperative Agreements United States Department of Housing and Urban Development Assistance Listing Number: 14.218 Community Development Block Grants United States Department of Homeland Security Assistance Listing Number: 97.024 Emergency Food and Shelter Criteria: In accordance with CFR §200.303(a), Internal Controls, 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. These internal controls should be in compliance with 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)…”Additionally, in accordance with CFR §200.303(a), Monitoring and reporting program performance, the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity…”CFR 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 CFR §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 provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 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 Financial Reporting and §200.329 Monitoring and Reporting Program Performance.Records that identify adequately the source and application of funds for federally funded activities. Effective control over, and accountability for, all funds, property, and other assets. United Way of Greater Cleveland is required to submit its Single Audit Report to the Federal Audit Clearinghouse within 30 calendar days after the receipt of the Auditor’s report, or within nine months after the close of the Auditee’s fiscal year, whichever is earlier. Condition: Therefore, the submission to the Federal Audit Clearing House is subsequent to both 30 days from the date of the receipt of the financial statements and nine months after year end and is therefore considered a late submission. Cause: During the year ended June 30, 2023, United way of Greater Cleveland migrated general ledger financial reporting systems, which caused delays in the closing and financial audit process. Subsequent to June 30, 2023, United Way of Greater Cleveland experienced turnover in certain programmatic staff, which further delayed certain procedures related to ensuring sufficiency and accuracy of the SEFA, thus causing delays in the audit process. Effect: There was no effect due to the late submission of the report. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the United Way of Greater Cleveland’s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above.Repeat Finding: his is not a repeat finding. Recommendation:We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed and on a timely basis to allow for prompt submission to the FAC. Views of Responsible Officials: United Way of Greater Cleveland’s management agrees with the finding and recommendations set forth within and has developed a corrective action.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR §200.302(b)(3) which provides that the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally- funded activities. These records must contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR § 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 7 CFR §§ 210.7(c), 210.8(c), and 225.9(d)) provide that at a minimum, a claim must include the number of reimbursable meals/milk served by category and type during the period (generally a month) covered by the claim. All meals claimed for reimbursement must (a) be of types authorized by the school food authority’s, institution’s, or sponsor’s administering agency; (b) be served to eligible children; and (c) be supported by accurate meal counts and records indicating the number of meals served by category and type. Eleven percent of the site claim form submissions during fiscal year 2023 were underreported, resulting in an under-reimbursement of $9,043. These errors occurred due to a weakness in internal controls, which failed to ensure site claim forms for reimbursable meals served at each building and submitted by the District to the Ohio Department of Education were entered correctly. The District should implement policies and procedures to help ensure that monthly site claim forms are reviewed and submitted to reflect actual counts for reimbursable meals served. Further, measures should be taken to ensure staff completing the site claim forms are adequately trained.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR §200.302(b)(3) which provides that the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally- funded activities. These records must contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR § 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 7 CFR §§ 210.7(c), 210.8(c), and 225.9(d)) provide that at a minimum, a claim must include the number of reimbursable meals/milk served by category and type during the period (generally a month) covered by the claim. All meals claimed for reimbursement must (a) be of types authorized by the school food authority’s, institution’s, or sponsor’s administering agency; (b) be served to eligible children; and (c) be supported by accurate meal counts and records indicating the number of meals served by category and type. Eleven percent of the site claim form submissions during fiscal year 2023 were underreported, resulting in an under-reimbursement of $9,043. These errors occurred due to a weakness in internal controls, which failed to ensure site claim forms for reimbursable meals served at each building and submitted by the District to the Ohio Department of Education were entered correctly. The District should implement policies and procedures to help ensure that monthly site claim forms are reviewed and submitted to reflect actual counts for reimbursable meals served. Further, measures should be taken to ensure staff completing the site claim forms are adequately trained.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR §200.302(b)(3) which provides that the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally- funded activities. These records must contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR § 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 7 CFR §§ 210.7(c), 210.8(c), and 225.9(d)) provide that at a minimum, a claim must include the number of reimbursable meals/milk served by category and type during the period (generally a month) covered by the claim. All meals claimed for reimbursement must (a) be of types authorized by the school food authority’s, institution’s, or sponsor’s administering agency; (b) be served to eligible children; and (c) be supported by accurate meal counts and records indicating the number of meals served by category and type. Eleven percent of the site claim form submissions during fiscal year 2023 were underreported, resulting in an under-reimbursement of $9,043. These errors occurred due to a weakness in internal controls, which failed to ensure site claim forms for reimbursable meals served at each building and submitted by the District to the Ohio Department of Education were entered correctly. The District should implement policies and procedures to help ensure that monthly site claim forms are reviewed and submitted to reflect actual counts for reimbursable meals served. Further, measures should be taken to ensure staff completing the site claim forms are adequately trained.
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR §200.302(b)(3) which provides that the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally- funded activities. These records must contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR § 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 7 CFR §§ 210.7(c), 210.8(c), and 225.9(d)) provide that at a minimum, a claim must include the number of reimbursable meals/milk served by category and type during the period (generally a month) covered by the claim. All meals claimed for reimbursement must (a) be of types authorized by the school food authority’s, institution’s, or sponsor’s administering agency; (b) be served to eligible children; and (c) be supported by accurate meal counts and records indicating the number of meals served by category and type. Eleven percent of the site claim form submissions during fiscal year 2023 were underreported, resulting in an under-reimbursement of $9,043. These errors occurred due to a weakness in internal controls, which failed to ensure site claim forms for reimbursable meals served at each building and submitted by the District to the Ohio Department of Education were entered correctly. The District should implement policies and procedures to help ensure that monthly site claim forms are reviewed and submitted to reflect actual counts for reimbursable meals served. Further, measures should be taken to ensure staff completing the site claim forms are adequately trained.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.
Assistance Listing Number(s): 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce Development Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31, 2024; June 20, 2022 through June 30, 2025 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in 2 CFR sections 200.328 and 200.329. Condition and Context: A sample of 4 financial and programmatic reports totaling $204,255 was selected for testing from a population of 20 financial and programmatic reports totaling $900,466. The testing found no support of a review and approval for completeness and accuracy. 4 out of 18 financial reports tested had reported amounts that were not supported by the underlying accounting data. 2 of the 4 had expenses recorded as staffing and repairs and maintenance but were reported as supplies. 1 of the 4 had expenses recorded as supplies but reported as personnel. 1 of the 4 reported other subaward costs as subrecipient expenditures. Cause: There are no written procedures for reporting to require internal controls over reporting or documentation supporting reports to be filed and maintained. Recording expenses in the general ledger by award began in the fiscal year. Reports were not reconciled to the general ledger, the general ledger accounts were not structured to match the budgets, and budgets grouped expenses together that should be reported separately. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Questioned Costs: $180,975; $4,462 for expenses that were reported greater than budget without prior approval; $176,157 of reported subrecipient costs that are unsupported in the general ledger; $356 of reported supplies that were repairs and maintenance and not included in the budget. Repeat Finding: No. Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.
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 $302 of expenditures at 6/30/23. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on one function object code by a cumulative amount of $302. Under 2550-500, total expenditures were $89,698 but District claimed $90,000, resulting in an overclaim of $302. Questioned Costs: $302. Context: The District claimed expenditures that did not agree with their underlying accounting records. Effect: The District was not compliant with reporting requirements. Inaccurate reporting resulted in the District being reimbursed for an additional $302 as of 6/30/23. As a result of the overclaim, federal expenditures were reduced on the SEFA from $2,077,163 to $2,076,861. Cause: The District claimed expenditures based on the amount of the purchase order, which differed slightly from the actual payment amount. 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 District.
Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency 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: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency 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 adopted the appropriate policies and procedures in December 2023.
Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency 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: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency 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 adopted the appropriate policies and procedures in December 2023.
Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency 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: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency 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 adopted the appropriate policies and procedures in December 2023.
Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency 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: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency 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 adopted the appropriate policies and procedures in December 2023.
Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency 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: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency 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 adopted the appropriate policies and procedures in December 2023.
Finding 2023-001 Year-End Close Process/Account Reconciliations Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 the financial management system of each non-Federal entity must provide for 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: The fiscal year-end schedules supporting various asset and liability accounts were incorrectly prepared and required revision, resulting in significant adjustments to NEW's unaudited financial statements. Multiple trial balances were received throughout the audit process. A significant amount of time was spent by management during the audit process reconciling accounts resulting in an audit delay. The delay resulted in additional audit work performed after the original end date of the initial field work. These issues most likely resulted in management and the Board reviewing unreliable internal financial information throughout the year, and this also represents a deficiency in adhering to NEW's internal control policies and procedures. Cause: A proper internal controls process, which would include a supervisory review and approval process (with physical or electronic evidence of such a process), was not in place during the fiscal year under audit.Effect or Potential Effect: Significant adjustments were proposed by management during the audit. Additionally, any internal financial statements produced by management during the year (and as of fiscal year-end) were not properly stated in relation to the financial statements taken as a whole (and therefore could not be relied upon). Questioned Costs: None Context: Our audit procedures consisted of an initial review of the financial statements and related supporting schedules, which led to management having to perform multiple subsequent reviews (and corrections) following attempts to correct earlier provided schedules and financial statements. The condition noted is deemed to be systematic in nature. Identification as a Repeat Finding, if Applicable: Finding 2022-001 Recommendation: We recommend that NEW ensure that each account is properly reconciled on a monthly basis.
Finding 2023-002: Support for Schedule of Expenditures of Federal Awards in the Accounting System Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 (financial management) the auditee must be able to identify all Federal awards received and expenses and the Federal programs under which they were received. Condition: Detailed invoices were available to support the amounts reported on the Schedule of Expenditures of Federal Awards (SEFA), however the expenses had not been accurately classified by award within the general ledger. It is not possible to extract a program income statement to support the expenditures reported for each program from the accounting system. Cause: Although they do have categories set up by program, NEW was not tracking the charges reimbursed by the Federal Government separately within the general ledger. Effect or Potential Effect: If the information on the SEFA cannot be traced back to the information within the accounting system, there is an increased potential for inaccurate reporting. Questioned Costs: Indeterminable Context: The account structure was not set up to track the expenses charged to the Federal Government. Identification as a Repeat Finding, if Applicable: Finding 2022-002 Recommendation: We recommend that NEW ensure that support for the Schedule of Expenditures of Federal Awards (SEFA) can be extracted from the accounting system (i.e. a program income statement).
Finding 2023-001 Year-End Close Process/Account Reconciliations Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 the financial management system of each non-Federal entity must provide for 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: The fiscal year-end schedules supporting various asset and liability accounts were incorrectly prepared and required revision, resulting in significant adjustments to NEW's unaudited financial statements. Multiple trial balances were received throughout the audit process. A significant amount of time was spent by management during the audit process reconciling accounts resulting in an audit delay. The delay resulted in additional audit work performed after the original end date of the initial field work. These issues most likely resulted in management and the Board reviewing unreliable internal financial information throughout the year, and this also represents a deficiency in adhering to NEW's internal control policies and procedures. Cause: A proper internal controls process, which would include a supervisory review and approval process (with physical or electronic evidence of such a process), was not in place during the fiscal year under audit.Effect or Potential Effect: Significant adjustments were proposed by management during the audit. Additionally, any internal financial statements produced by management during the year (and as of fiscal year-end) were not properly stated in relation to the financial statements taken as a whole (and therefore could not be relied upon). Questioned Costs: None Context: Our audit procedures consisted of an initial review of the financial statements and related supporting schedules, which led to management having to perform multiple subsequent reviews (and corrections) following attempts to correct earlier provided schedules and financial statements. The condition noted is deemed to be systematic in nature. Identification as a Repeat Finding, if Applicable: Finding 2022-001 Recommendation: We recommend that NEW ensure that each account is properly reconciled on a monthly basis.
Finding 2023-002: Support for Schedule of Expenditures of Federal Awards in the Accounting System Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 (financial management) the auditee must be able to identify all Federal awards received and expenses and the Federal programs under which they were received. Condition: Detailed invoices were available to support the amounts reported on the Schedule of Expenditures of Federal Awards (SEFA), however the expenses had not been accurately classified by award within the general ledger. It is not possible to extract a program income statement to support the expenditures reported for each program from the accounting system. Cause: Although they do have categories set up by program, NEW was not tracking the charges reimbursed by the Federal Government separately within the general ledger. Effect or Potential Effect: If the information on the SEFA cannot be traced back to the information within the accounting system, there is an increased potential for inaccurate reporting. Questioned Costs: Indeterminable Context: The account structure was not set up to track the expenses charged to the Federal Government. Identification as a Repeat Finding, if Applicable: Finding 2022-002 Recommendation: We recommend that NEW ensure that support for the Schedule of Expenditures of Federal Awards (SEFA) can be extracted from the accounting system (i.e. a program income statement).
Finding 2023-001 Year-End Close Process/Account Reconciliations Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 the financial management system of each non-Federal entity must provide for 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: The fiscal year-end schedules supporting various asset and liability accounts were incorrectly prepared and required revision, resulting in significant adjustments to NEW's unaudited financial statements. Multiple trial balances were received throughout the audit process. A significant amount of time was spent by management during the audit process reconciling accounts resulting in an audit delay. The delay resulted in additional audit work performed after the original end date of the initial field work. These issues most likely resulted in management and the Board reviewing unreliable internal financial information throughout the year, and this also represents a deficiency in adhering to NEW's internal control policies and procedures. Cause: A proper internal controls process, which would include a supervisory review and approval process (with physical or electronic evidence of such a process), was not in place during the fiscal year under audit.Effect or Potential Effect: Significant adjustments were proposed by management during the audit. Additionally, any internal financial statements produced by management during the year (and as of fiscal year-end) were not properly stated in relation to the financial statements taken as a whole (and therefore could not be relied upon). Questioned Costs: None Context: Our audit procedures consisted of an initial review of the financial statements and related supporting schedules, which led to management having to perform multiple subsequent reviews (and corrections) following attempts to correct earlier provided schedules and financial statements. The condition noted is deemed to be systematic in nature. Identification as a Repeat Finding, if Applicable: Finding 2022-001 Recommendation: We recommend that NEW ensure that each account is properly reconciled on a monthly basis.
Finding 2023-002: Support for Schedule of Expenditures of Federal Awards in the Accounting System Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 (financial management) the auditee must be able to identify all Federal awards received and expenses and the Federal programs under which they were received. Condition: Detailed invoices were available to support the amounts reported on the Schedule of Expenditures of Federal Awards (SEFA), however the expenses had not been accurately classified by award within the general ledger. It is not possible to extract a program income statement to support the expenditures reported for each program from the accounting system. Cause: Although they do have categories set up by program, NEW was not tracking the charges reimbursed by the Federal Government separately within the general ledger. Effect or Potential Effect: If the information on the SEFA cannot be traced back to the information within the accounting system, there is an increased potential for inaccurate reporting. Questioned Costs: Indeterminable Context: The account structure was not set up to track the expenses charged to the Federal Government. Identification as a Repeat Finding, if Applicable: Finding 2022-002 Recommendation: We recommend that NEW ensure that support for the Schedule of Expenditures of Federal Awards (SEFA) can be extracted from the accounting system (i.e. a program income statement).
Finding 2023-001 Year-End Close Process/Account Reconciliations Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 the financial management system of each non-Federal entity must provide for 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: The fiscal year-end schedules supporting various asset and liability accounts were incorrectly prepared and required revision, resulting in significant adjustments to NEW's unaudited financial statements. Multiple trial balances were received throughout the audit process. A significant amount of time was spent by management during the audit process reconciling accounts resulting in an audit delay. The delay resulted in additional audit work performed after the original end date of the initial field work. These issues most likely resulted in management and the Board reviewing unreliable internal financial information throughout the year, and this also represents a deficiency in adhering to NEW's internal control policies and procedures. Cause: A proper internal controls process, which would include a supervisory review and approval process (with physical or electronic evidence of such a process), was not in place during the fiscal year under audit.Effect or Potential Effect: Significant adjustments were proposed by management during the audit. Additionally, any internal financial statements produced by management during the year (and as of fiscal year-end) were not properly stated in relation to the financial statements taken as a whole (and therefore could not be relied upon). Questioned Costs: None Context: Our audit procedures consisted of an initial review of the financial statements and related supporting schedules, which led to management having to perform multiple subsequent reviews (and corrections) following attempts to correct earlier provided schedules and financial statements. The condition noted is deemed to be systematic in nature. Identification as a Repeat Finding, if Applicable: Finding 2022-001 Recommendation: We recommend that NEW ensure that each account is properly reconciled on a monthly basis.
Finding 2023-002: Support for Schedule of Expenditures of Federal Awards in the Accounting System Information on the Federal Programs: ALN 14.235 Criteria or Specific Requirement: In accordance with CFR 200.302 (financial management) the auditee must be able to identify all Federal awards received and expenses and the Federal programs under which they were received. Condition: Detailed invoices were available to support the amounts reported on the Schedule of Expenditures of Federal Awards (SEFA), however the expenses had not been accurately classified by award within the general ledger. It is not possible to extract a program income statement to support the expenditures reported for each program from the accounting system. Cause: Although they do have categories set up by program, NEW was not tracking the charges reimbursed by the Federal Government separately within the general ledger. Effect or Potential Effect: If the information on the SEFA cannot be traced back to the information within the accounting system, there is an increased potential for inaccurate reporting. Questioned Costs: Indeterminable Context: The account structure was not set up to track the expenses charged to the Federal Government. Identification as a Repeat Finding, if Applicable: Finding 2022-002 Recommendation: We recommend that NEW ensure that support for the Schedule of Expenditures of Federal Awards (SEFA) can be extracted from the accounting system (i.e. a program income statement).
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management’s grant tracking of expenditures for the federal awards was not clearly classified during the year. Cause: Due to continued staff turnover, sufficient training for preparing grant tracking spreadsheets is still necessary for new staff and only the federal awards received during the year were maintained and cleared defined. It is unknown as to what the actual expenditures for each program were for the year and it is assumed that all federal awards received were expensed. Effect or Potential Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Repeat Finding: Yes Recommendation: We recommend the Organization provide training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, we recommend reconciliations be performed monthly between the grant spreadsheets and the financial reporting software. A tracking of the federal expenditures need to be kept and classified to proper federal program. Views of Responsible Officials: Management agrees with the finding and will provide training and implement procedures to ensure the grant tracking spreadsheets are reviewed appropriately.
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management’s grant tracking of expenditures for the federal awards was not clearly classified during the year. Cause: Due to continued staff turnover, sufficient training for preparing grant tracking spreadsheets is still necessary for new staff and only the federal awards received during the year were maintained and cleared defined. It is unknown as to what the actual expenditures for each program were for the year and it is assumed that all federal awards received were expensed. Effect or Potential Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Repeat Finding: Yes Recommendation: We recommend the Organization provide training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, we recommend reconciliations be performed monthly between the grant spreadsheets and the financial reporting software. A tracking of the federal expenditures need to be kept and classified to proper federal program. Views of Responsible Officials: Management agrees with the finding and will provide training and implement procedures to ensure the grant tracking spreadsheets are reviewed appropriately.
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management’s grant tracking of expenditures for the federal awards was not clearly classified during the year. Cause: Due to continued staff turnover, sufficient training for preparing grant tracking spreadsheets is still necessary for new staff and only the federal awards received during the year were maintained and cleared defined. It is unknown as to what the actual expenditures for each program were for the year and it is assumed that all federal awards received were expensed. Effect or Potential Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Repeat Finding: Yes Recommendation: We recommend the Organization provide training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, we recommend reconciliations be performed monthly between the grant spreadsheets and the financial reporting software. A tracking of the federal expenditures need to be kept and classified to proper federal program. Views of Responsible Officials: Management agrees with the finding and will provide training and implement procedures to ensure the grant tracking spreadsheets are reviewed appropriately.
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management’s grant tracking of expenditures for the federal awards was not clearly classified during the year. Cause: Due to continued staff turnover, sufficient training for preparing grant tracking spreadsheets is still necessary for new staff and only the federal awards received during the year were maintained and cleared defined. It is unknown as to what the actual expenditures for each program were for the year and it is assumed that all federal awards received were expensed. Effect or Potential Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Repeat Finding: Yes Recommendation: We recommend the Organization provide training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, we recommend reconciliations be performed monthly between the grant spreadsheets and the financial reporting software. A tracking of the federal expenditures need to be kept and classified to proper federal program. Views of Responsible Officials: Management agrees with the finding and will provide training and implement procedures to ensure the grant tracking spreadsheets are reviewed appropriately.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, except for 2 CFR § 200.102(a) and 2 CFR § 200.207(a). Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. 2 CFR § 200.329(a) provides that the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity. See also § 200.332. 2 CFR § 200.302(b)(2) provides, in part, that the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. 2 CFR § 200.332(d) provides, in part, that a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial and performance reports required by the pass-through entity. The Ohio Department of Education requires school districts to file a Final Expenditure Report each year by September 30, unless stated otherwise in the grant application. ODE further requires subgrantees to obligate funds within the approved project period as set forth in the approved application and to liquidate said obligations not later than 90 days after the end of the project period for electronic applications for grants, with obligations having the same meaning as in 2 CFR §§ 200.343 and 200.1. ODE also requires all allowable grant expenditures obligated by the project end date as designated in the grant agreement to be reported in the FER. The District did file the Final Expenditure Report with ODE before the required reporting deadline, however, due to deficiencies in the internal policies and procedures over Federal compliance, the District did not exclude the prior grant year expenditures obligated during the prior fiscal year, but not paid until after June 30, 2022. This resulted in expenditures being overreported in the amount of $78,795; however, this oversight did not result in additional federal funding. Failure to file accurate financial information in the Final Expenditure Report could lead to material misstatements and could impact future grant funding. The District should review the Final Expenditure Report before submission to help ensure all required amounts are included.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, except for 2 CFR § 200.102(a) and 2 CFR § 200.207(a). Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. 2 CFR § 200.329(a) provides that the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity. See also § 200.332. 2 CFR § 200.302(b)(2) provides, in part, that the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. 2 CFR § 200.332(d) provides, in part, that a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial and performance reports required by the pass-through entity. The Ohio Department of Education requires school districts to file a Final Expenditure Report each year by September 30, unless stated otherwise in the grant application. ODE further requires subgrantees to obligate funds within the approved project period as set forth in the approved application and to liquidate said obligations not later than 90 days after the end of the project period for electronic applications for grants, with obligations having the same meaning as in 2 CFR §§ 200.343 and 200.1. ODE also requires all allowable grant expenditures obligated by the project end date as designated in the grant agreement to be reported in the FER. The District did file the Final Expenditure Report with ODE before the required reporting deadline, however, due to deficiencies in the internal policies and procedures over Federal compliance, the District did not exclude the prior grant year expenditures obligated during the prior fiscal year, but not paid until after June 30, 2022. This resulted in expenditures being overreported in the amount of $78,795; however, this oversight did not result in additional federal funding. Failure to file accurate financial information in the Final Expenditure Report could lead to material misstatements and could impact future grant funding. The District should review the Final Expenditure Report before submission to help ensure all required amounts are included.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) 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. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) ALN: 10.170, Specialty Crop Block Grant ALN: 15.228, National Fire Plan ALN 10.767: Intermediary Relending Program (IRP) ALN 66.818: Brownfields RLF ALN 11.307: Economic Development Assistance RLF Criteria: The Code of Federal Regulations (CFR) 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. CFR 200.302(b)(1) requires that the nonfederal entity must identify in its accounts and on the schedule of expenditures of federal awards all federal awards received and expended, as well as the federal programs under which they were received. Federal program and award identification must include, as applicable, the Assistance Listing program title and number, the federal award identification number and year, the name of the federal agency, and the name of the pass-through entity, if any. Condition: The Specialty Crop Block Grant was left off of the prepared SEFA. Amounts reported for the National Fire Plan grant, IRP, and Brownfields RLF did not agree to the accounting records. The amount reported for the Economic Development Assistance RLF was not calculated in accordance with the compliance supplement calculation formula. Context: There SEFA was understated or overstated by ALN as follows: • Understated by $14,123 for the omission of the Specialty Crop Block Grant; • Overstated by $1,942 for National Fire Plan grant; • Understated by $10,748 for IRP; • Understated by $25,902 for Brownfields RLF; and • Overstated by $101,804 for Economic Development Assistance RLF. The net effect was an overstatement of $52,973. Effect: The SEFA provided was not complete and fully accurate. Questioned Costs: None. Cause: The internal controls for the preparation of the SEFA and review of the SEFA were not present to ensure the SEFA was complete and accurate. Auditor Recommendation: We recommend the Organization prepare procedures on how to put together the SEFA and strengthen internal controls to ensure all federal awards are included on the SEFA. We also recommend that staff who administer federal funds review the SEFA for completeness and accuracy before providing it to the auditor. Organization Response: The organization disagrees with the reported deficiency related to the SEFA preparation on the basis that the task was an agreed nonattest service contracted to Douglas Wilson & Company, P.C. The noted modifications are outcomes of these services and are not indicative of control deficiencies. With respect to the nonattest services, the Organization has fulfilled the responsibilities stated in the engagement letter to assume all management responsibilities for the services; to have those services overseen by an individual with appropriate skills, knowledge, and experience; evaluate the adequacy of the services; and to accept responsibility for them. Since its inception, the organization’s auditors have prepared the SEFA under the same engagement letters executed with the auditor. The organization’s outsourced accounting firm, JCCS, also provides these nonattest services for their auditees and were operating under the same understanding of this service arrangement. Management reports that this finding is a result of a misunderstanding between Management, JCCS, and Douglas Wilson & Company, P.C. regarding which party would complete the SEFA. Based on the signed engagement letter, Management understood that completing the SEFA was part of the auditors’ nonattest services. Their outsourced accounting firm, JCCS, provided a draft SEFA to the auditors with communication that it was a draft and would need to be finalized. JCCS worked directly with the auditor in making the necessary changes and finalizing the SEFA. Management nor JCCS were aware that the auditor would be identifying this collaboration as a material weakness. Management strongly disagrees that this finding has anything to do with a deficiency in internal controls as they understood they had engaged the auditor to provide this nonattest service. Management reports a discussion with the auditor that such a misunderstanding presented as an internal control deficiency carries significant consequences for the organization's future Federal awards. It is important that the organization's Federal grantors understand the full context of this finding.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the ESSER and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the ESSER and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the ESSER and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the ESSER and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the ESSER and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the ESSER and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the ESSER and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the ESSER and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the ESSER and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the ESSER and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
2023-007 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance 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 or the conditions of the Federal award. Condition: The City 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 City’s procedures did not ensure the required written procedures were developed and implemented in accordance with the Uniform Guidance. Effect: The City has not compiled with Title 2 CFR Section 200.302(b)(7) regarding establishing written procedures for determining the allowability of costs. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The condition above was identified during our procedures related to allowable costs. Repeat Finding from Prior Year: No Recommendation: We recommend the City establish policies and formalize written procedures related to allowable costs in accordance with Subpart E – Cost Principles. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.