FINDING 2023-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction, of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation's records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation's ledger had total expenses for the award, for that time period, of $784,638. INDIANA STATE BOARD OF ACCOUNTS 18 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were isolated to the ESSER III, Year 2 report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. 19 INDIANA STATE BOARD OF ACCOUNTS OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all expenditures are reported on the reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction, of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation's records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation's ledger had total expenses for the award, for that time period, of $784,638. INDIANA STATE BOARD OF ACCOUNTS 18 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were isolated to the ESSER III, Year 2 report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 report was not supported by the School Corporation's records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. 19 INDIANA STATE BOARD OF ACCOUNTS OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all expenditures are reported on the reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-010 – Material Weakness and Material Noncompliance, Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Assistance Listing Program Title and Number- Disaster Grants- Public Assistance (Presidentially Declared Disasters) 97.036 Federal Agency- Department of Homeland Security Pass-through Entity- N/A Award year: 2023 Criteria or specific requirement: Recipients must follow 2 CFR section 200.302 and the Public Assistance Program and Policy Guide which require documentation must be maintained for all costs claimed by the recipient regarding internal controls, allowable activities and eligible costs and recipients must incur such costs by the period of performance deadline of May 11, 2023. Condition: The City could not provide records related to the claimed costs within the force account labor and materials populations for the COVID-19 program portion of ALN 97.036. Cause: There has been turnover in grants department personnel and lack of policies and procedures to ensure the required level of documentation was maintained. Additionally, there was a change in general ledger systems during the fiscal year that attributed to a disconnect in the audit trail. Effect: The City can not demonstrate they complied with federal grant requirements over activities allowed or unallowed, allowable costs/cost principles and period of performance. Lack of support could result in actions taken by oversight agencies to claw back funding, or to reduce future funding. Context: The City could not provide support for 36 out of 40 force account labor selections, totaling $54,767 and $56,963, respectively. The City could not provide complete support for six out of 40 materials selections, totaling $53,421 and $186,993, respectively. Total Force Account Labor and Materials expenditures for this ALN were $1,840,561 out of the total expenditures of $4,208,353 reported on the SEFA. The samples were not statistically valid samples. Questioned Costs: Known questioned costs totaling $108,188 based on 36 unsupported payroll items within a sample size of 40 and 6 unsupported invoices with a sample size of 40 in the Force Account labor and materials populations, respectively. Repeating Finding: No. Recommendation We recommend that the City develop processes and procedures to ensure proper tracking of force account labor at the employee level as well as maintain copies of all supporting invoices or other support for non-payroll expenditures as required. Views of Responsible Officials: Management agrees with the finding.
CASH MANAGEMENT - CASH DRAWS Repeat of finding 2022-003 Finding Type: Material Weakness in Internal Controls over Compliance, Material Noncompliance ALN/CSFA and Program Title: 93.676 – Unaccompanied Alien Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Liberty Wilderness Crossroads Camp Contract Number: 90ZU0362 (direct), 90ZU0501 Criteria: Under 2 CFR 200.305(b) of the Uniform Guidance, non-federal entities “must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Under 2 CFR 200.305(b)(5) of the Uniform Guidance, “To the extent available, the non-federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.” Under 2 CFR 200.302(b)(6) of the Uniform Guidance, the Organization’s financial management system must provide for “written procedures to implement the requirements of 2 CFR 200.305.” Additionally, 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Organization drew cash down in excess of the total program disbursements during the year ended June 30, 2023, and requested additional cash draws prior to disbursing available funds for this program. Additionally, the Organization did not have written cash management policies and there was no process established for reviewing the pay requests prepared prior to submission. Cause: Policies and procedures were not in place to ensure that the time elapsing between the transfer of federal funds to the Organization and the disbursement of such funds for program purposes was minimized. In addition, policies and procedures were not in place to ensure that additional cash draws were not requested prior to disbursing all available funds for program related purposes. Effect: Program funds were drawn in excess of disbursements. The Organization could be required to return the excess funds to the grantor along with any associated earned interest, until such time as the money is legitimately needed to pay for grant activities. Questioned Costs: None Recommendation: We recommend that written policies and procedures be established to implement the requirements of 2 CFR 200.305, and recommend procedures be established for review of the cash draw requests prior to submission and that the review be documented. Views of Responsible Officials and Planned Corrective Actions: See management’s response and Corrective Action Plan on page 57.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Foster Care Title IV-E Federal Assistance Listing Number: 93.658 Compliance Requirements: Activities allowed or unallowed, Allowable costs/Cost Principles Type of Finding: Significant Deficiencies in Internal Control over Compliance Federal Award Identification Number and Year: 2201CAFOST 2023 Criteria: According to 2 CFR, Part 200.302(b)(3), recipients of federal awards are responsible for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition/Context: In connection with the Activities allowed or unallowed, and Allowable Costs/Cost Principles compliance requirements for the Foster Care Title IV-E grant we noted that management was unable to locate one approved invoices out of 40 items selected for test work. Cause: Due to turnover in the accounting department some accounting records became misplaced and current accounting staff could not locate these records. Effect or Potential Effect: Failure to ensure expenses are being accurately supported and recorded could result in non-compliance with the grant requirements or unallowable costs being charged. Questioned Costs: Questioned costs were not identified. Identification as a Repeat Finding This finding is not a repeat finding. Auditor's Recommendation: We recommend that management implement policies, procedures, and controls to ensure supporting documentation over expenses is properly retained and expenses charged to Federal awards are accurate. Views of Responsible Officials: Management understands the critical importance of maintaining proper documentation to ensure compliance with federal program requirements. To this end, the Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice and Payment Documentation: • All invoices related to the federal program will be promptly reviewed and approved by the appropriate personnel to ensure they reflect allowable costs under the specific terms and conditions of the award. • Management will establish clear procedures for the proper recording and classification of payments, ensuring that they are linked directly to the corresponding federal program expenses. • All supporting documentation (e.g., purchase orders, contracts, receipts) will be retained in electronic formats within the accounting system, in accordance with the Organization’s record retention policy, ensuring availability for future audits or reviews. Retention and Accessibility: • The Organization will maintain a secure, organized filing system for all invoices and payments, ensuring that each record is easily accessible for audit purposes. This system will include electronic records that are stored in a centralized database, with restricted access to authorized personnel. • Retained invoices and payment documentation will be kept for the full duration required by federal regulations, typically for a period of at least seven years after the final expenditure report for the federal award has been submitted, or as otherwise required by the specific federal agency. Periodic Reviews and Monitoring: • To ensure ongoing compliance, Management will perform periodic reviews of federal program expenditures and documentation. This will include random sampling of invoices and payment records to confirm that they are complete, accurate, and in compliance with federal regulations. • In the event of any discrepancies or issues identified during these reviews, Management will take immediate corrective action to address the issue and prevent recurrence. By maintaining thorough records of all invoices and payments, the Organization aims to not only comply with federal audit requirements but also to ensure transparency, accountability, and sound financial management of federal funds.
2023-003 – Allowable Costs/Cost Principles: Written Financial Policies Federal Program Information: Department of Transportation - ALN: - 20.500, 20.507, 20.525 & 20.526 – Federal Transit Cluster 20.509 – Formula Grants for Rural Areas and Tribal Transit Program Criteria: The following CFR(s) apply to this finding: 2 CFR Section 200.302(b), Condition: The Committee has not formally adopted certain required written financial management policies as outlined in the Code of Federal Regulations. Cause: The Committee was not aware of this requirement. Effect: Transactions could occur that did not comply with federal regulations. Identification of Questioned Costs: None identified. Context: The finding was based on requesting the Committee’s written financial policies related to federal compliance and therefore was not the result of a statistical sample. Repeat Finding: This is not a repeat finding. Recommendation: The auditor recommends that the Committee obtain an understanding of the required written policies in the Code of Federal Regulations as applicable to its federal programs, create and formally adopt those required policies. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Biddeford-Saco-Old Orchard Beach Transit Committee.
2023-002 Financial Management and Internal Controls (Continued) Compliance Requirement Allowable Costs/Cost Principles Category Significant Deficiency in Internal Control and Noncompliance Federal Agency U.S. Department of the Treasury Pass-Through Entity Puerto Rico Fiscal Agency and Financial Advisory Authority ALN 21.027 Federal Program COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Small Business Administration ALN 59.075 Federal Program COVID-19 - Shuttered Venue Operators Program Federal Agency U.S. Department of Homeland Security through the Federal Emergency Management Agency Pass-Through Entity Central Office for Recovery, Reconstruction and Resiliency ALN 97.036 Federal Program Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause In 2022, the Corporation became subject to Single Audit compliance requirements for the first time. However, it underestimated the complexity of navigating the intricate laws, regulations, and financial management requirements associated with federal funds. The lack of prior experience in implementing adequate internal controls, coupled with the absence of established written policies, contributed to challenges in ensuring compliance with federal cost principles and financial reporting obligations. Effect Failure to comply with 2 CFR sections 200.302 and 200.305 could result in the Corporation incurring unallowable costs. Consequently, the Corporation may face temporary withholding of cash payments until the deficiency is corrected. Additionally, continued noncompliance could lead to further sanctions, including the suspension or termination of federal funding for the program, ultimately impacting the Corporation’s ability to fulfill its obligations and sustain operations. Questioned Costs None. Repeated Item Refer to Item No. 2022-002 in the Summary Schedule of Prior Audit Findings. Recommendation The Corporation should draft written policies under subpart E, Cost Principles of 2 CFR Part 200. In addition, the staff involved with federal funds should take courses on federal awards. Views of responsible officials Refer to Unaudited Corrective Action Plan.
Federal Program: Head Start Cluster (CFDA 93.600) Federal Agency: U.S. Department of Health and Human Services Federal Award Number(s): 08CH012021-02-01 Compliance Requirement: Allowable Costs/Cost Principles Questioned Costs: $125 Condition – During testing of expenditures charged to the Head Start program several transactions were identified for which adequate supporting documentation such as invoices, receipts, or other evidence demonstrating the nature and purpose of the expenditures could not be provided. Criteria – Under 2 CFR 200.403(g) costs charged to federal awards must be adequately documented to be allowable. Additionally, 2 CFR 200.302(b)(3) requires non-federal entities to maintain records that “identify adequately the source and application of funds” for federally funded activities. Cause – Internal control procedures were not consistently followed related to retaining supporting documentation for federal program expenditures. Control over documentation retention was not sufficiently designed or monitored to ensure that all required records were maintained and readily available. Effect – Inadequate documentation increases the risk that unallowable costs may be charged to the federal program and may result in disallowed costs or repayment to the federal awarding agency. Recommendation – We recommend that the government strengthen its internal controls over documentation retention for federal program expenditures and ensure staff is knowledgeable regarding Uniform Guidance documentation requirements. Client Response – Management acknowledges this finding. We no longer service this program. In the future if we take a grant of this size on, training will be held for any employees involved with the grant. Status of Finding – This is not a repeat finding from the prior year.
CONDITION: During our testing over the Tiger IX Grant, we noted the County did not submit the reports required by the grant agreement by the due dates. We noted the County’s quarterly progress reports were submitted on the following dates: • Period from 7/1/2022-9/30/2022 was submitted on 6/5/2023 • Period from 10/1/2022-12/31/2022 was submitted on 2/7/2023 • Period from 1/1/2023-3/31/2023 was submitted on 6/5/2023 • Period from 4/1/2023-6/30/2023 was submitted on 8/2/2023 CRITERIA: According to §200.302 Financial management of 2 CFR Part 200, the state’s and the other 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. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to §200.303 Internal controls of 2 CFR Part 200, 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. Per the County’s grant agreement (agreement #69A3652040160TIINM) the County is required to submit quarterly project progress reports and recertifications on or before the 20th day of the first month of each calendar quarter and until Project Closeout. The County is also required to submit quarterly financial reports on or before the 30th day of each calendar quarter and until the period of performance end date covering the previous calendar year quarter. EFFECT: The auditor noted instances of non-compliance. Non-compliance results in delayed reimbursements of eligible Federal expenditures. CAUSE: The County did not establish or apply appropriate internal controls over federal funding requirements. RECOMMENDATION: We recommend that the County establish appropriate controls over federal monies in the future to ensure compliance with federal grant requirements. MANAGEMENT’S RESPONSE: Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. County Manager and Financial Specialist were not trained in Railroad project management. Changes in staff within the County Manager’s Office and private corporations as well as state and federal agencies resulted in change in requirements, poor communication, and delay in reporting ultimately resulting in disruption of reimbursement to the County. Colfax County worked with NM Department of Transportation and Federal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County. RESPONSIBLE PARTY/TIMELINE TO CORRECT: County Manager’s Office has been able to establish open communication with key players in gathering important information used for reporting. Colfax County has also hired a Grant/Special Projects Manager to oversee and maintain all County grants and special projects. Timeline to correct will be June 30, 2024.
FINDING 2023-005 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Match, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 26 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Earmarking A portion of the School Corporation's Title I allocation is required to be reserved for parental involvement and homeless reservation, as specified in the Title I grant application. The School Corporation is responsible for monitoring these set-asides throughout the grant period to ensure compliance. While monitoring was completed on the reimbursement requests, the requests, though reviewed by a knowledgeable employee, were supported by summary level payroll data. This level of detail was insufficient to confirm that the appropriate employees were charged to the designated Title I funds. Additionally, the School Corporation did not spend the Homeless Student set-aside amount per the Title I application and did not carry over the funds to provide services to students experiencing homelessness in the subsequent school year, along with reserving funds from the next year's grant award. The lack of internal controls and noncompliance was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." INDIANA STATE BOARD OF ACCOUNTS 27 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 6313(c)(3)(A) states: "A local educational agency shall reserve such funds as are necessary under this part, determined in accordance with subparagraphs (B) and (C), to provide services comparable to those provided to children in schools funded under this part to serve - (i) homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live; (ii) children in local institutions for neglected children; and (iii) if appropriate, children in local institutions for delinquent children, and neglected or delinquent children in community day programs." Cause The School Corporation did not have adequate internal controls to ensure compliance with Title I set-aside requirements. Monitoring procedures relied on summary level payroll documentation, which did not provide sufficient detail to verify that employees charged to Title I were allowable and properly assigned. Additionally, the School Corporation lacked a formal process to track, monitor, and ensure timely use or carryover of the Homeless Student set-aside funds, resulting in noncompliance with the approved Title I application. Effect The lack of detailed payroll documentation and insufficient monitoring of Title I set-asides resulted in the School Corporation being unable to demonstrate that payroll expenditures charged to Title I were accurate, allowable, or aligned with the approved grant budget. The failure to spend or carry over the required Homeless Student set-aside funds limits services available to students' experiencing homelessness. These deficiencies increase the risk of questioned costs, required corrective actions, and potential restrictions on future grant funding, while also creating additional administrative burden during the audit due to the need for expanded testing and follow-up. Questioned Costs There were no questioned costs identified. Recommendation The School Corporation should strengthen internal controls by requiring detailed, employee-level payroll documentation to support all Title I charges and ensure reviewers verify that expenditures align with the approved grant budget. In addition, the School Corporation should implement a formal process to track all Title I set-asides, including parental involvement and homeless reservations, throughout the grant period. Procedures should also be established to ensure the timely use or proper carryover of homeless student set-aside funds in accordance with federal regulations and the approved Title I application. Additionally, the School Corporation should provide necessary support and resources to staff responsible for ensuring grant compliance and helping to prevent similar issues in future grant cycles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-006 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. Condition and Context The School Corporation was required to submit reimbursement requests and final expenditure reports that included, among other data, both current and prior period expenditures. However, the required reports for federal awards did not capture all activity for the reporting period and were not supported by the School Corporation's records. Reimbursement Requests The School Corporation uses reimbursement requests to claim allowable expenses paid from Title I funds. These requests must be based on and supported by transactions recorded within the School Corporation's Title I accounts. Summary-level reports were generated from the School Corporation's financial system by the Director of Federal Grants for the reimbursement period and attached to the reimbursement request. While reimbursement requests were to be prepared by the Director of Federal Grants and reviewed by the Title I Director or Title I Budget Supervisor, no evidence of this review or oversight process was available. Of the four reimbursement requests selected for testing, three could not be verified against either the summary-level detail attached to the request or a detailed transaction listing. Because the amounts requested for reimbursement could not be traced to underlying records or to reports that accumulated or summarized the data, the accuracy and completeness of the reimbursement requests could not be verified. Final Expenditure Reports Final expenditure reports were expected to be prepared by the Director of Federal Grants using year-to-date expenditure data and reviewed by either the Director of Internal Audit or the Title I Budget Supervisor. However, no evidence was available to show that this review or oversight process took place. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 29 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation did not design or implement an effective internal control system to ensure the accuracy and compliance of reimbursement and final expenditure reporting processes. Specifically, the School Corporation did not have established procedures requiring the retention of detailed supporting documentation for reimbursement requests, and oversight responsibilities were not consistently carried out or evidenced over the reimbursement requests and final expenditure reports. Additionally, the employee responsible for preparing reimbursement requests during the audit period did not maintain the required documentation, and no secondary review process was in place to detect or correct these deficiencies. INDIANA STATE BOARD OF ACCOUNTS 30 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Because the School Corporation did not retain detailed documentation to support reimbursement requests or provide evidence of the required review of final expenditure reports, the audit team could not verify the accuracy, allowability, or completeness of expenditures charged to the grant. These gaps in documentation increased the audit time and administrative burden, as additional testing and follow-up were necessary to address missing records. As a result, the risk of misreporting, misallocation of federal funds, and potential violations of grant requirements were significantly heightened. Questioned Costs There were no questioned costs identified. Recommendation The School Corporation should establish and implement a formal internal control system to ensure accurate financial reporting and compliance with federal grant requirements. This system should include documented review procedures, clear segregation of duties, and consistent oversight of reimbursement requests and expenditure reports. All financial submissions should be supported by verifiable documentation and reconciled with internal records prior to submission. Additionally, the School Corporation should provide necessary support and resources to staff responsible for ensuring grant compliance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U, 84.425C, 84.425W Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013, S425C200018, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-007. INDIANA STATE BOARD OF ACCOUNTS 37 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted one ESSER I report, one ESSER II report, and one ESSER III report, for a total of three reports. An effective internal control system was not in place at the School Corporation to ensure these reports were accurate. As such, the annual data reports were prepared and submitted to the IDOE without an oversight or review process to prevent or detect and correct errors. All three reports submitted during the audit period were not supported by the School Corporation's records. The following errors were identified: The ESSER I, Year 3 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $1,526,046 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,601,347. The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $10,293,210 in expenditures. However, actual expenditures for the applicable reporting period totaled $9,750,555. The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $15,939,167 in expenditures. However, actual expenditures for the applicable reporting period totaled $17,220,521. During the audit period, the School Corporation also received eight total reimbursements related to the COVID-19 - Education Stabilization Fund grant. The School Corporation received two GEER reimbursements, two ESSER I reimbursements, two ESSER II reimbursements, two ESSER III reimbursements, and 2 ARP HCY reimbursements. All reimbursement request forms were tested against the School Corporations records for accuracy. Of the eight reimbursements requested, six forms tested were not supported by the School Corporation's records. The following errors were identified: GEER reimbursement requests forms were overstated by $3,580 compared to the School Corporation's records. ESSER I reimbursement request forms were $860,284 overstated compared to the School Corporation's records. ESSER II reimbursement request forms were overstated by $221,808 compared to the School Corporation's records. ESSER III reimbursement request forms were understated by $220,484 compared to the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 38 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation did not establish or implement a properly designed internal control system, including appropriate segregation of duties, to ensure the accuracy and reliability of financial data submitted to the IDOE. The absence of formal review procedures, oversight mechanisms, and reconciliation processes resulted in the submission of materially misstated annual data reports and reimbursement requests. Contributing factors included inadequate staff training on federal reporting requirements, the lack of documented financial reporting policies, and insufficient allocation of resources to monitor compliance with grant guidelines. Effect As a result, the annual data reports submitted to the IDOE via JotForm were materially misstated and lacked proper support from the School Corporation's financial records. Additionally, six out of eight reimbursement request forms tested during the audit period were either overstated or understated, reflecting inconsistent and inaccurate financial reporting tied to federal grant activity. These systemic errors represent significant noncompliance and undermine the reliability of reporting used for state and federal oversight. INDIANA STATE BOARD OF ACCOUNTS 39 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified Recommendation The School Corporation should strengthen its financial reporting processes related to federal grant activity by implementing a formal internal control system that ensures accuracy, consistency, and proper documentation. This includes reconciling financial records with data submitted through JotForm, establishing review procedures for reimbursement requests, and assigning qualified personnel to verify all reports prior to submission. Staff responsible for grant management and financial reporting should receive necessary support and resources regarding federal documentation standards and reporting requirements. The School Corporation should adopt standardized documentation policies and procedures across all departments to ensure compliance and oversight. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria or Specific Requirement: 2 CFR §200.302(b)(3) and §200.403(g) require that recipients maintain records sufficient to substantiate expenditures of federal awards and ensure that costs are adequately documented. Condition: During testing of expenditures for the Crime Victim Assistance Program, we noted that supporting documentation (e.g., invoices or payroll detail) for a number of transactions was incomplete or unavailable. Context: We tested a sample of 40 expenses out of 2,913 expenses during the year. Questioned Costs: No known or likely questioned costs exceed $25,000 Effect: Although alternative audit procedures were performed to verify the reasonableness and allowability of the costs, incomplete documentation indicates a weakness in recordkeeping controls. However, the number and dollar value of affected transactions were not material to the Crime Victim Assistance Program as a whole, and no questioned costs were identified. Cause: The organization experienced turnover in financial management positions and converted accounting systems multiple times during the audit period. During these transitions, some historical documentation was not migrated to the current system or retained in accessible form. Recommendation: We recommend that Safe Harbor Crisis Center strengthen its document retention policies and ensure that all grant-related supporting documentation is archived in a centralized electronic system accessible to both management and auditors, particularly during staff transitions or system conversions. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct his which is further discussed in the corrective action plan. Corrective Action Plan: See Corrective Action Plan prepared by Management.
SIGNIFICANT DEFICIENCY 2023-006 - Cash Management Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.302(b)(6)) & 2 CFR section 200.305(b) (3). Condition: During audit procedures, it was identified that the Town did not have a cash management policy in place. Cause: The Town has experienced turnover in the Treasurer’s position over the past few years, which has delayed the policy implementation. Effect: The Town may not have adequate policy and procedures in place to safeguard its most liquid assets. Identification of Questioned Costs: None identified. Context: The population consisted of 6 out of 10 pay requisites deposit of reimbursements from the fiscal year were examined. Out of the 6 selections all 6 were not properly recorded. Repeat Finding: This is a repeat finding of 2022-007. Recommendation: It is recommended that the Town adopt a cash management policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
Criteria: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. Condition: City of Cascade Locks has not developed written procedures for determining the allowability of costs. Cause: Administration did not have written procedures for determining the allowability of costs. Effect: Unallowable costs could be charged to the program. Questioned Costs: None Perspective: Written procedures for determining the allowability of costs is integral to the proper design of internal controls. However, the results of audit procedures did not detect any costs which are not allowable charged to the program. Recommendations: Management should develop written procedures as required by 2 CFR Part 200.302(b)(7). Views of Responsible Officials The City agrees that written procedures determining the allowability of costs should be developed. Despite this lack of procedure, the City is mindful that no funds were misappropriated during this audit.
Finding 2023.006: Cash Management - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID -19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program COVID-19 Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number and Year: H8026638 - 2022 and 2023, H8F40829 - 2021 and H8G48040-2023 Criteria In accordance with §200.305, Federal Payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect or Potential Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 7 drawdowns for testing of cash management. We noted there was no formal approval or evidence of review for all 7 drawdowns. Identification of Repeat Finding Yes, see finding 2022.006. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Federal Program: Workforce Investment Opportunity Act Cluster Assistance Listing 17.258 WIOA Adult Program Assistance Listing 17.259 WIOA Youth Activities Assistance Listing 17.278 WIOA Dislocated Worker Formula Grants Pass-Through Entity Identifying Number: 05-P19-Youth-81/05-P20-Youth-81 05-F20-Adult-81/05-F21-Adult-81/05-F22-Adult-81 05-F20-DLW-81/05-F21-DLW-81/05-F22-DLW-81 Federal Agency: U.S. Department of Labor Criteria or specific requirement: 2 CFR 200.302(b)(7) requires written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of federal awards. 2 CFR 200.303 requires the entity to establish and maintain effective internal control over federal awards. Under 2 CFR 200.403(c), (d), and (g), costs must be treated consistently, follow policies and procedures that apply uniformly to federal and non-federal activities, and be adequately documented. Under 2 CFR 200.405, a cost is allocable only to the extent the related goods or services benefit the federal award, and costs benefiting multiple activities must be distributed in proportions that can be approximated using reasonable methods. 2 CFR 200.430 requires salary and wage charges to be based on records that accurately reflect work performed and to be supported by a system of internal control. Under 2 CFR 200.414(f), an eligible entity may elect the 10% de minimis indirect cost rate applicable for the audit period. When applying the de minimis rate, costs must be consistently charged as either direct or indirect costs and may not be double charged or inconsistently charged as both. Condition: Management has not established a written cost allocation plan or policy as required by Uniform Guidance. Specifically, the Organization lacks documented procedures that define direct and indirect costs, describe how costs will be identified and classified, outline the methodology used to allocate indirect costs among active federal awards, and address the application of the 10% de minimis indirect cost rate. As a result, there is no formal framework to support the consistent allocation of costs to federal programs or to demonstrate compliance with federal requirements. Cause: The Organization had not established, approved, and implemented a comprehensive written cost allocation plan in accordance with Uniform Guidance requirements. As of June 30, 2023, management had not formalized policies and procedures governing the identification and classification of direct and indirect costs, the methodologies used to allocate indirect costs among federal awards, the documentation required to support cost allocations, or the application of the 10% de minimis indirect cost rate. Effect or potential effect: Because the Organization does not maintain a written cost allocation policy or plan, it lacks sufficient controls to ensure costs charged to federal awards are properly identified, allocated, and documented in accordance with Uniform Guidance. As a result, costs charged to federal programs may not be allocable to the benefiting awards, indirect costs could be inconsistently treated as direct costs, and noncompliance with Federal cost principles may not be prevented or detected in a timely manner. Questioned costs: $0 Context: The Organization operated without a written cost allocation policy as required by the Uniform Guidance. In addition, there is not sufficient documentation to support the allocation basis for indirect cost expenditures charged to WIOA. Identification as a Repeat Finding, if Applicable: No
2023-001: Reconciliations and Material Adjustments Questioned Costs: None How the questioned costs were computed: N/A Grant Funding Source Grant Period Head Start U.S. Department of Health 06/01/2022 - 05/31/2023 10CH010945-04 and Human Services Early Head Start U.S. Department of Health 07/01/2022 - 06/30/2023 Child Care Partnerships and Human Services 10HP000422-03 COVID-19 Head Start U.S. Department of Health 04/01/2021 - 03/31/2024 10HE000845-01 and Human Services COVID-19 Early Head U.S. Department of Health 07/01/2021 - 06/30/2022 Start Child Care and Human Services Partnerships 10HP000422-02-C3 Condition: At the time of audit fieldwork, Umatilla-Morrow Head Start, Inc. had not reconciled all account balances. As a result, Wipfli, LLP proposed and management posted adjusting journal entries to contributions receivable, grants receivable, refundable advance, property and equipment, grant revenue, and in-kind. During our tests of controls over bank reconciliations we also noted one individual is responsible for preparing the bank reconciliation, this individual also has the ability to post journal entries and there is no review of the completed bank reconciliation. As Umatilla-Morrow Head Start, Inc.’s internal controls did not discover these adjustments prior to our audit and as there is a lack of segregation of duties within the bank reconciliation process, a material weakness exists in Umatilla-Morrow Head Start, Inc.’s internal controls over financial reporting. Criteria: Federal Regulation 2 CFR 200.302(4) requires that an organization have…Effective control over, and accountability for, all funds, property, and other assets. Cause: During the audit year, Umatilla-Morrow Head Start, Inc. experienced turnover in its business office which contributed to the lack of timely reconciliations, review of reconciliations performed, and subsequent adjustments to account balances. Effect: As a result of the lack of segregation of duties surrounding bank reconciliations and not reconciling all account balances resulting in subsequent adjustments to accounts, a material weakness exists in internal controls over financial reporting. Recommendation: Accounts should be reconciled monthly with the adjustments posted timely so that management is relying on accurate financial information to make decisions. We recommend management and those charged with governance evaluate the operation of the business office and implement adequate and timely closing procedures to ensure that financial statement amounts are being reconciled, reviewed, and adjusted in a timely manner. View of Responsible Officials: Management agrees with the assessment and subsequent to year end, steps were taken to correct the matter.
2023-001: Reconciliations and Material Adjustments Questioned Costs: None How the questioned costs were computed: N/A Grant Funding Source Grant Period Head Start U.S. Department of Health 06/01/2022 - 05/31/2023 10CH010945-04 and Human Services Early Head Start U.S. Department of Health 07/01/2022 - 06/30/2023 Child Care Partnerships and Human Services 10HP000422-03 COVID-19 Head Start U.S. Department of Health 04/01/2021 - 03/31/2024 10HE000845-01 and Human Services COVID-19 Early Head U.S. Department of Health 07/01/2021 - 06/30/2022 Start Child Care and Human Services Partnerships 10HP000422-02-C3 Condition: At the time of audit fieldwork, Umatilla-Morrow Head Start, Inc. had not reconciled all account balances. As a result, Wipfli, LLP proposed and management posted adjusting journal entries to contributions receivable, grants receivable, refundable advance, property and equipment, grant revenue, and in-kind. During our tests of controls over bank reconciliations we also noted one individual is responsible for preparing the bank reconciliation, this individual also has the ability to post journal entries and there is no review of the completed bank reconciliation. As Umatilla-Morrow Head Start, Inc.’s internal controls did not discover these adjustments prior to our audit and as there is a lack of segregation of duties within the bank reconciliation process, a material weakness exists in Umatilla-Morrow Head Start, Inc.’s internal controls over financial reporting. Criteria: Federal Regulation 2 CFR 200.302(4) requires that an organization have…Effective control over, and accountability for, all funds, property, and other assets. Cause: During the audit year, Umatilla-Morrow Head Start, Inc. experienced turnover in its business office which contributed to the lack of timely reconciliations, review of reconciliations performed, and subsequent adjustments to account balances. Effect: As a result of the lack of segregation of duties surrounding bank reconciliations and not reconciling all account balances resulting in subsequent adjustments to accounts, a material weakness exists in internal controls over financial reporting. Recommendation: Accounts should be reconciled monthly with the adjustments posted timely so that management is relying on accurate financial information to make decisions. We recommend management and those charged with governance evaluate the operation of the business office and implement adequate and timely closing procedures to ensure that financial statement amounts are being reconciled, reviewed, and adjusted in a timely manner. View of Responsible Officials: Management agrees with the assessment and subsequent to year end, steps were taken to correct the matter.
2023-001: Reconciliations and Material Adjustments Questioned Costs: None How the questioned costs were computed: N/A Grant Funding Source Grant Period Head Start U.S. Department of Health 06/01/2022 - 05/31/2023 10CH010945-04 and Human Services Early Head Start U.S. Department of Health 07/01/2022 - 06/30/2023 Child Care Partnerships and Human Services 10HP000422-03 COVID-19 Head Start U.S. Department of Health 04/01/2021 - 03/31/2024 10HE000845-01 and Human Services COVID-19 Early Head U.S. Department of Health 07/01/2021 - 06/30/2022 Start Child Care and Human Services Partnerships 10HP000422-02-C3 Condition: At the time of audit fieldwork, Umatilla-Morrow Head Start, Inc. had not reconciled all account balances. As a result, Wipfli, LLP proposed and management posted adjusting journal entries to contributions receivable, grants receivable, refundable advance, property and equipment, grant revenue, and in-kind. During our tests of controls over bank reconciliations we also noted one individual is responsible for preparing the bank reconciliation, this individual also has the ability to post journal entries and there is no review of the completed bank reconciliation. As Umatilla-Morrow Head Start, Inc.’s internal controls did not discover these adjustments prior to our audit and as there is a lack of segregation of duties within the bank reconciliation process, a material weakness exists in Umatilla-Morrow Head Start, Inc.’s internal controls over financial reporting. Criteria: Federal Regulation 2 CFR 200.302(4) requires that an organization have…Effective control over, and accountability for, all funds, property, and other assets. Cause: During the audit year, Umatilla-Morrow Head Start, Inc. experienced turnover in its business office which contributed to the lack of timely reconciliations, review of reconciliations performed, and subsequent adjustments to account balances. Effect: As a result of the lack of segregation of duties surrounding bank reconciliations and not reconciling all account balances resulting in subsequent adjustments to accounts, a material weakness exists in internal controls over financial reporting. Recommendation: Accounts should be reconciled monthly with the adjustments posted timely so that management is relying on accurate financial information to make decisions. We recommend management and those charged with governance evaluate the operation of the business office and implement adequate and timely closing procedures to ensure that financial statement amounts are being reconciled, reviewed, and adjusted in a timely manner. View of Responsible Officials: Management agrees with the assessment and subsequent to year end, steps were taken to correct the matter.
2023-001: Reconciliations and Material Adjustments Questioned Costs: None How the questioned costs were computed: N/A Grant Funding Source Grant Period Head Start U.S. Department of Health 06/01/2022 - 05/31/2023 10CH010945-04 and Human Services Early Head Start U.S. Department of Health 07/01/2022 - 06/30/2023 Child Care Partnerships and Human Services 10HP000422-03 COVID-19 Head Start U.S. Department of Health 04/01/2021 - 03/31/2024 10HE000845-01 and Human Services COVID-19 Early Head U.S. Department of Health 07/01/2021 - 06/30/2022 Start Child Care and Human Services Partnerships 10HP000422-02-C3 Condition: At the time of audit fieldwork, Umatilla-Morrow Head Start, Inc. had not reconciled all account balances. As a result, Wipfli, LLP proposed and management posted adjusting journal entries to contributions receivable, grants receivable, refundable advance, property and equipment, grant revenue, and in-kind. During our tests of controls over bank reconciliations we also noted one individual is responsible for preparing the bank reconciliation, this individual also has the ability to post journal entries and there is no review of the completed bank reconciliation. As Umatilla-Morrow Head Start, Inc.’s internal controls did not discover these adjustments prior to our audit and as there is a lack of segregation of duties within the bank reconciliation process, a material weakness exists in Umatilla-Morrow Head Start, Inc.’s internal controls over financial reporting. Criteria: Federal Regulation 2 CFR 200.302(4) requires that an organization have…Effective control over, and accountability for, all funds, property, and other assets. Cause: During the audit year, Umatilla-Morrow Head Start, Inc. experienced turnover in its business office which contributed to the lack of timely reconciliations, review of reconciliations performed, and subsequent adjustments to account balances. Effect: As a result of the lack of segregation of duties surrounding bank reconciliations and not reconciling all account balances resulting in subsequent adjustments to accounts, a material weakness exists in internal controls over financial reporting. Recommendation: Accounts should be reconciled monthly with the adjustments posted timely so that management is relying on accurate financial information to make decisions. We recommend management and those charged with governance evaluate the operation of the business office and implement adequate and timely closing procedures to ensure that financial statement amounts are being reconciled, reviewed, and adjusted in a timely manner. View of Responsible Officials: Management agrees with the assessment and subsequent to year end, steps were taken to correct the matter.
Federal Agency: US Department of Housing and Urban Development Federal Program Title: Community Development Block Grants/Entitlement Grants ALN Number: 14.228 Award Periods: April 1, 2022 March 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance also reported as Other Noncompliance Criteria or specific requirement: 2 CFR Subpart D 200.302 (1) and 200.303 (a) stipulates that the auditee must identify, in its accounts, all Federal awards received and expended and the Federal programs under which they were received. Federal programs and award identification shall include, as applicable, the ALN title and number, Federal award identification number and year, name of Federal agency, and name of the pass-through entity; establish and maintain effective internal control over Federal award that provides reasonable assurance that the auditee is managing Federal awards in compliance with Federal statutes, regulation, 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 Controller General of the United States and the Internal Control Integrated Framework, issued by the Committee on Sponsoring Organizations of the Treadway Commission (COSO). In addition, 2 CFR 200.502(b) states that since the Federal Government is at risk for loans until the debt is repaid, the following guidelines must be used to calculate the value of Federal awards expended under loan programs, except as noted in paragraphs (c) and (d) of this section: (1) Value of new loans made or received during the audit period; plus (2) Beginning of the audit period balance of loans from previous years for which the Federal Government imposes continuing compliance requirements; plus (3) Any interest subsidy, cash, or administrative cost allowance received. Condition: The Authoritys schedule of expenditures of federal awards (SEFA) did not report loan balances on the SEFA as required by Uniform Guidance for federal program 14.228. Questioned costs: Not able to determine. Context: The Agency did not report loan balances on the SEFA. Cause: The Agency was not aware of the requirements to include loan balances on the SEFA. Effect: The SEFA omitted loan balances for federal program 14.228. Therefore, it was not in compliance with 2 CFR Subpart D 200.302 (1), 200.303 (a) and 200.502 (b). The Agencys program expenditures may be disallowed if the expenditures are not reported correctly on the SEFA. Recommendation: We recommend that the Agency review current procedures for creating the SEFA to ensure that it is accurately reporting loan balances and expenditures during the year under audit for all federal programs to ensure compliance with Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
Cash Management Public Housing Capital Fund - AL No. 14.872 Significant Deficiency in Internal Controls Other Matter to Reported Under the Uniform Control Condition: It was noted that funds were overdrawn during the year and never paid out to a vendor. Out of the 26 grant drawdowns during the year, 11 samples were tested and the following was noted: 6 drawdowns were missing invoice documentation. 4 drawdowns were missing payment documentation. Context: The auditor haphazardly selected 11 grant drawdowns from the population, which we consider to be a statistically valid sample size. The auditor reviewed the drawdowns and supporting documentation to ensure proper procedures are being followed and that the Authority is in compliance with HUD requirements. Criteria: The U.S. Treasury per 2 CFR section 200.305 (2 CFR section 200.302(b)(6)) requires grant funds received by the Authority to be properly spent within 72 hours of receipt. HUD regulations require that proper documentation be maintained for all Capital Fund Program per 24 CFR 905.326. Cause: The Authority experienced staff turnover in the finance department as well as difficulty replacing personnel knowledgeable with HUD and grant reporting requirements. Effect: The Authority is unable to provide supporting documentation for the capital funds that were drawn during the year. Questioned Costs: $155,318 Auditor’s Recommendations: The Authority should continue to develop and implement internal controls over grant reporting and provide training opportunities to staff. View of Responsible Officials: See Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 66.458, Environmental Protection Agency. Capitalization Grants for Clean Water State Revolving Funds Federal Award Identification Number and Year: 5749-01, Loan Period 06/18/2022-11/15/2024 Pass-through Entity: Michigan Department of Environment, Great Lakes, and Energy Finance Division - Water Infrastructure Financing Section Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. Such policies should include procedures for collecting payments of federal funds per 2 CRF 200.305, cash management (i.e., minimizing the time between draws and actual disbursing of federal awards) per 2 CFR 200.302(b)(6), allowable cost per 2 CFR 200.403, and conflict of interest per 2 CFR 200.318. Per 2 CFR 200.319 (d), the non-Federal entity must have written procedures for procurement transactions. Condition: The Township did not have written procedures for cash management, allowable cost or conflict of interest. In addition, the Township procurement policy did not include all necessary items specified in the Uniform Guidance. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None Context: N/A Cause/Effect: The Township was not aware that they were required to have written policies and procedures for the items noted above and was using the grant agreement requirements for guidelines. The Township's controls were not adequate to ensure it followed the federal requirement over these processes. Recommendation: We recommend the Township adopt written policies and procedures over cash management, allowable costs, and conflicts of interest. In addition, we recommend that management review and modify the procedure policy to include all the necessary items outline in the Uniform Guidance. View of responsible officials and planned corrective action plan: See attached corrective action plan.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Federal Agency: US Department of Housing and Urban Development Federal Program Title: Community Development Block Grants/Entitlement Grants ALN Number: 14.228 Award Periods: April 1, 2022 March 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance also reported as Other Noncompliance Criteria or specific requirement: 2 CFR Subpart D 200.302 (1) and 200.303 (a) stipulates that the auditee must identify, in its accounts, all Federal awards received and expended and the Federal programs under which they were received. Federal programs and award identification shall include, as applicable, the ALN title and number, Federal award identification number and year, name of Federal agency, and name of the pass-through entity; establish and maintain effective internal control over Federal award that provides reasonable assurance that the auditee is managing Federal awards in compliance with Federal statutes, regulation, 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 Controller General of the United States and the Internal Control Integrated Framework, issued by the Committee on Sponsoring Organizations of the Treadway Commission (COSO). In addition, 2 CFR 200.502(b) states that since the Federal Government is at risk for loans until the debt is repaid, the following guidelines must be used to calculate the value of Federal awards expended under loan programs, except as noted in paragraphs (c) and (d) of this section: (1) Value of new loans made or received during the audit period; plus (2) Beginning of the audit period balance of loans from previous years for which the Federal Government imposes continuing compliance requirements; plus (3) Any interest subsidy, cash, or administrative cost allowance received. Condition: The Authoritys schedule of expenditures of federal awards (SEFA) did not report loan balances on the SEFA as required by Uniform Guidance for federal program 14.228. Questioned costs: Not able to determine. Context: The Agency did not report loan balances on the SEFA. Cause: The Agency was not aware of the requirements to include loan balances on the SEFA. Effect: The SEFA omitted loan balances for federal program 14.228. Therefore, it was not in compliance with 2 CFR Subpart D 200.302 (1), 200.303 (a) and 200.502 (b). The Agencys program expenditures may be disallowed if the expenditures are not reported correctly on the SEFA. Recommendation: We recommend that the Agency review current procedures for creating the SEFA to ensure that it is accurately reporting loan balances and expenditures during the year under audit for all federal programs to ensure compliance with Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
Cash Management Public Housing Capital Fund - AL No. 14.872 Significant Deficiency in Internal Controls Other Matter to Reported Under the Uniform Control Condition: It was noted that funds were overdrawn during the year and never paid out to a vendor. Out of the 26 grant drawdowns during the year, 11 samples were tested and the following was noted: 6 drawdowns were missing invoice documentation. 4 drawdowns were missing payment documentation. Context: The auditor haphazardly selected 11 grant drawdowns from the population, which we consider to be a statistically valid sample size. The auditor reviewed the drawdowns and supporting documentation to ensure proper procedures are being followed and that the Authority is in compliance with HUD requirements. Criteria: The U.S. Treasury per 2 CFR section 200.305 (2 CFR section 200.302(b)(6)) requires grant funds received by the Authority to be properly spent within 72 hours of receipt. HUD regulations require that proper documentation be maintained for all Capital Fund Program per 24 CFR 905.326. Cause: The Authority experienced staff turnover in the finance department as well as difficulty replacing personnel knowledgeable with HUD and grant reporting requirements. Effect: The Authority is unable to provide supporting documentation for the capital funds that were drawn during the year. Questioned Costs: $155,318 Auditor’s Recommendations: The Authority should continue to develop and implement internal controls over grant reporting and provide training opportunities to staff. View of Responsible Officials: See Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 66.458, Environmental Protection Agency. Capitalization Grants for Clean Water State Revolving Funds Federal Award Identification Number and Year: 5749-01, Loan Period 06/18/2022-11/15/2024 Pass-through Entity: Michigan Department of Environment, Great Lakes, and Energy Finance Division - Water Infrastructure Financing Section Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. Such policies should include procedures for collecting payments of federal funds per 2 CRF 200.305, cash management (i.e., minimizing the time between draws and actual disbursing of federal awards) per 2 CFR 200.302(b)(6), allowable cost per 2 CFR 200.403, and conflict of interest per 2 CFR 200.318. Per 2 CFR 200.319 (d), the non-Federal entity must have written procedures for procurement transactions. Condition: The Township did not have written procedures for cash management, allowable cost or conflict of interest. In addition, the Township procurement policy did not include all necessary items specified in the Uniform Guidance. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None Context: N/A Cause/Effect: The Township was not aware that they were required to have written policies and procedures for the items noted above and was using the grant agreement requirements for guidelines. The Township's controls were not adequate to ensure it followed the federal requirement over these processes. Recommendation: We recommend the Township adopt written policies and procedures over cash management, allowable costs, and conflicts of interest. In addition, we recommend that management review and modify the procedure policy to include all the necessary items outline in the Uniform Guidance. View of responsible officials and planned corrective action plan: See attached corrective action plan.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
Assistance Listing Number: 93.224 U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers; COVID-19 American Rescue Plan Act Funding for Health Centers Finding Type: Significant Deficiency Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs. Condition/Context: For 1 of the Center’s 92 expense reimbursement request draw-downs for the year ended March 31, 2023, the reimbursement request included more expenses than the amount of respective expenses incurred. Cause: During the year, the Center experienced turnover within the finance department and expense reimbursement requests were inadvertently completed incorrectly using incorrect allocations percentages and information. Effect: As a result of the incorrect expense reimbursements, the Center received reimbursement payments in excess of related expenses incurred totaling $199,099 for the year ended March 31, 2023. Questioned Costs: $199,099 Recommendation: The Center should implement a more robust process and related internal controls surrounding the expense reimbursement requests to ensure that the submitted requests agree to the respective costs incurred and supported. Views of Responsible Officials: Due to extenuating circumstances, including turnover in the finance department, the reimbursement requests were not properly reviewed and agreed to supporting documentation. However, although the expense reimbursement requests exceeded the respective incurred expenses in the identified requests above, the Center consistently incurs allowable expenses that qualify to be reimbursed in excess of total grant payments received and is working to remediate the issue. Planned Implementation of Corrective Action: Additional preventative internal control procedures will be implemented, including and additional level of review of the reimbursement request prior to submission. These procedures and internal controls have been implemented as of the date of this report. Person responsible for Corrective Action: Chief Executive Officer.
2023-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness This is a repeat finding. The prior-year’s auditing finding number is 2022-012. Condition: A weakness existed in the overall reconciliation/tie-in procedures performed over the Housing Authority’s financial statement accounts for the fiscal year ended March 31, 2023. Financial accounts were not reconciled on a timely, monthly basis. The major areas where reconciliation procedures were weak included: A) Bank Reconciliations B) Grant Receivables C) Account Receivables and associated allowance for doubtful accounts D) Capital Assets E) Accounts Payable F) Payroll and Other Current Liabilities Criteria: OMB Uniform Guidance states the following in section 200.302, “(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. Cause: Lack of written policies and procedures over financial tie-in procedures that identify who is responsible for performing these tie-in/reconciliation procedures. Effect: In the course of performing the audit, the auditor recommended 4 adjusting journal entries be made to the financial statements for fiscal year ending March 31, 2022. Many of these adjustments could have been avoided if timely reconciliation and tie-in procedures had been conducted by the finance department. Many of these audit adjustments were material in nature. Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Views of Responsible Officials: See Corrective Action Plan.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.
Criteria: The Organizations are required under 2 CFR §200.302 to be able to have “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received”. It is also required to maintain “effective control over, and accountability for, all funds, property, and other assets”. These requirements are imperative to ensure that all Federal programs are properly reported on the Organizations’ Schedule of Expenditures of Federal Awards (SEFA). Condition: During our audit, we noted a few Federal programs that had expired in prior years were inadvertently included in the SEFA by error due to failure of reallocating expenditures to the proper Federal programs. Additionally, the Vaccines for Children program and a portion of the required Period 4 Provider Relief Fund receipts was not included in the original SEFA prepared by the Center. Cause: Due to significant turnover in the finance department and lack of accountability and monitoring of Federal funds, the Center did not properly report the Federal expenditures in the SEFA. This situation is due primarily to the fact that there is not a designated individual responsible and accountable for ensuring that all Federal sources of funds are properly identified and monitored in accordance with the laws and regulations, contracts, and grant agreements. Effect or Potential Effect: Without sufficient internal controls surrounding the preparation of the SEFA and an understanding of all programs that are Federally funded, the SEFA could be inaccurately reported. Questioned Costs: None. Context: The Center failed to properly track and allocate Federal expenditures in fiscal year 2022, which resulted in the SEFA not being properly prepared. Additionally, the Center did not have a person with the appropriate knowledge of the Vaccines for Children program or SEFA receipt reporting requirements of the Provider Relief Fund programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop standard operating procedures (SOPs) to document the current processes, procedures, and contingency plans to improve daily operations, efficiency, productivity, compliance, and risk management. Additionally, we recommend that the Center implement policies and procedures to ensure that expenses are allocated to the appropriate Federal grant award/program so the SEFA can be prepared to accurately reflect expenses incurred. We also recommend that the Center identify and monitor all Federal source of funds (including Federally sourced donated vaccines) and ensure they have oversight/monitoring and are being properly reported.