2020-002– INTERNAL CONTROL OVER COMPLIANCE MATERIAL WEAKNESS CRITERIA Per Uniform Guidance (2 CFR Part 200.302), the grantee must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the grantee is managing the Federal award in compliance with statutes, regulations, and the terms and conditions of the Federal award. CONDITION The Authority did not maintain proper monitoring, communication and control activities to ensure adherence to the Authority’s key administrative policies including procurement, occupancy and the HCV administrative plan. The Authority outsourced the management of the Housing Choice Voucher and Mainstream Voucher programs and did not properly monitor the activities of the those programs. The third party management company adopted and maintained policies and procedures for the Authority without board approval. CAUSE The Authority did not have proper oversight of their Housing Choice Voucher and Mainstream Voucher programs. EFFECT This deficiency in internal controls resulted in material noncompliance, which could affect the Authority's ability to manage and report on Federal awards accurately. QUESTIONED COSTS None noted. CONTEXT We reviewed the Authority’s internal controls over compliance with federal awards. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Authority’s management take an active role in reviewing the their policies and monitoring the Authority’s compliance with those policies. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Criteria Per 2 CFR 200.302 (b)(7) a non-federal entity must establish written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles and the terms and conditions of the Federal award. Per 2 CFR 200.303, a 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 the 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). Article 12 of the Act 83 of May 2, 1941, as amended, establishes that the Authority must have an accounting system that provides for adequate control and statistical records of all income and expenses from, administered or controlled by the Authority. Condition and Context During our review of the internal controls over compliance, we noted that the following: • Authority did not have written procedures or formal policies to ensure compliance over the Allowable Costs and Cost Principles, Period of Performance, Matching and Reporting requirements. • During our test work over internal controls over compliance for activities allowed and cost principles requirements, we noted that the Authority implemented a system of compiling the relevant data elements, including allowed expenditures for all projects. However, there was no control addressing the completeness and accuracy of the allowed expenditures. Cause and Possible Asserted Effect Management did not establish proper internal controls to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Absence of formal policies and procedures could cause the Authority to fall in noncompliance with federal awards. Also, the Authority’s processes and controls are not designed to ensure proper review of supporting documentation to meet the compliance requirements of the Federal Grant. Not having formal processes and controls caused that in multiple occasions the Grantor returned claims submitted due to lack of support documentation. Questioned Cost There were no questioned costs associated with the finding. Whether the Sampling was a Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Prior Year Repeat Finding A similar finding was reported in the prior year’s audit as finding 2019-008. Recommendation Management must establish written procedures and formal policies to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. View of Responsible Officials Management acknowledges the findings and has implemented a corrective action plan to enhance compliance with Federal awards. This plan includes developing Standard Operating Procedures (SOPs) for grant management activities, identifying, and documenting existing internal controls, and maintaining constant communication with stakeholders to prevent material non-compliance. Additionally, PREPA will provide training to staff on the new SOPs and establish a monitoring mechanism to continuously assess and improve the effectiveness of these controls. The corrective action plan, supervised by Mr. Ezequiel Nieves from the PREPA Disaster Funding Management Office, is expected to be completed by July 2025. Management is committed to addressing deficiencies, ensuring that processes and controls are robust and effective, and that Federal awards are managed transparently and in full compliance with all regulatory requirements. The estimated date of completion is expected to be in July 2025. Responsible Party - Mr. Ezequiel Nieves - PREPA Disaster Funding Management Office, Finance Department. Effective June 1, 2021, the Authority transitioned the management and operation of its transmission and distribution network as well as certain back- office functions, including billing, collections and accounting, to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. Management will work to address these findings with the assistance of the third-party operators, where applicable. Also, effective July 1, 2023, the Authority transitioned the management and operation of its generation assets as well as certain back- office functions to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. In addition, the Authority will also be implementing and monitoring corrective actions taken by the new generation segment operator.
Criteria: According to 2 CFR §200.302, the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Internal controls over financial reporting and compliance involve procedures and mechanisms designed to ensure the accuracy, reliability and integrity of an Organization’s financial reporting and its adherence to laws and regulations. Condition: During our testing of the audit of activities allowed or unallowed and allowable costs/cost principles requirements, we noted two instances of a lack of supporting documentation for gas and mileage reimbursements. Upon further investigation, we noted that all requests and payments for gas and mileage reimbursements lacked the receipts, purpose, and requests for reimbursement. Cause: Program personnel did not adhere to the policies and procedures in maintaining supporting documentation and/or program personnel were not knowledgeable of the Organization’s policies and procedures and the requirements of 2 CFR §200.302. Effect: The Organization failed to maintain the supporting documentation necessary to validate the expense reimbursements and whether the expenditures were in compliance with 2 CFR §200.302.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Grantor: 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 CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials 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.
Criteria Per 2 CFR 200.302 (b)(7) a non-federal entity must establish written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles and the terms and conditions of the Federal award. Per 2 CFR 200.303, a 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 the 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). Article 12 of the Act 83 of May 2, 1941, as amended, establishes that the Authority must have an accounting system that provides for adequate control and statistical records of all income and expenses from, administered or controlled by the Authority. Condition and Context During our review of the internal controls over compliance, we noted that the following: • Authority did not have written procedures or formal policies to ensure compliance over the Allowable Costs and Cost Principles, Period of Performance, Matching and Reporting requirements. • During our test work over internal controls over compliance for activities allowed and cost principles requirements, we noted that the Authority implemented a system of compiling the relevant data elements, including allowed expenditures for all projects. However, there was no control addressing the completeness and accuracy of the allowed expenditures. Cause and Possible Asserted Effect Management did not establish proper internal controls to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Absence of formal policies and procedures could cause the Authority to fall in noncompliance with federal awards. Also, the Authority’s processes and controls are not designed to ensure proper review of supporting documentation to meet the compliance requirements of the Federal Grant. Not having formal processes and controls caused that in multiple occasions the Grantor returned claims submitted due to lack of support documentation. Questioned Cost There were no questioned costs associated with the finding. Whether the Sampling was a Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Prior Year Repeat Finding A similar finding was reported in the prior year’s audit as finding 2019-008. Recommendation Management must establish written procedures and formal policies to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. View of Responsible Officials Management acknowledges the findings and has implemented a corrective action plan to enhance compliance with Federal awards. This plan includes developing Standard Operating Procedures (SOPs) for grant management activities, identifying, and documenting existing internal controls, and maintaining constant communication with stakeholders to prevent material non-compliance. Additionally, PREPA will provide training to staff on the new SOPs and establish a monitoring mechanism to continuously assess and improve the effectiveness of these controls. The corrective action plan, supervised by Mr. Ezequiel Nieves from the PREPA Disaster Funding Management Office, is expected to be completed by July 2025. Management is committed to addressing deficiencies, ensuring that processes and controls are robust and effective, and that Federal awards are managed transparently and in full compliance with all regulatory requirements. The estimated date of completion is expected to be in July 2025. Responsible Party - Mr. Ezequiel Nieves - PREPA Disaster Funding Management Office, Finance Department. Effective June 1, 2021, the Authority transitioned the management and operation of its transmission and distribution network as well as certain back- office functions, including billing, collections and accounting, to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. Management will work to address these findings with the assistance of the third-party operators, where applicable. Also, effective July 1, 2023, the Authority transitioned the management and operation of its generation assets as well as certain back- office functions to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. In addition, the Authority will also be implementing and monitoring corrective actions taken by the new generation segment operator.
Criteria: According to 2 CFR §200.302, the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Internal controls over financial reporting and compliance involve procedures and mechanisms designed to ensure the accuracy, reliability and integrity of an Organization’s financial reporting and its adherence to laws and regulations. Condition: During our testing of the audit of activities allowed or unallowed and allowable costs/cost principles requirements, we noted two instances of a lack of supporting documentation for gas and mileage reimbursements. Upon further investigation, we noted that all requests and payments for gas and mileage reimbursements lacked the receipts, purpose, and requests for reimbursement. Cause: Program personnel did not adhere to the policies and procedures in maintaining supporting documentation and/or program personnel were not knowledgeable of the Organization’s policies and procedures and the requirements of 2 CFR §200.302. Effect: The Organization failed to maintain the supporting documentation necessary to validate the expense reimbursements and whether the expenditures were in compliance with 2 CFR §200.302.
2020-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness This is a repeat finding. The prior-year’s auditing finding number is 2019-007. 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, 2020. 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) Accounts Receivable and associated allowance for doubtful accounts D) Accounts Payable E) 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 9 adjusting journal entries be made to the financial statements for fiscal year ending March 31, 2020. 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.
2020-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness This is a repeat finding. The prior-year’s auditing finding number is 2019-007. 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, 2020. 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) Accounts Receivable and associated allowance for doubtful accounts D) Accounts Payable E) 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 9 adjusting journal entries be made to the financial statements for fiscal year ending March 31, 2020. 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.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Criteria: Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Condition: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Cause: Inaccurate accounting of grant expenditures in the City’s financial management system. Effect: The City did not consistently segregate and identify federal grant expenditures separately from their nonfederal expenditures. Questioned costs: There are no questioned costs associated with this finding. Context: The City needs to create and implement a policy to accurately account for federally funded activities separately from non-federally funded activities in their financial management system. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance.
Criteria: Under Uniform Guidance, pass-through entities must monitor subrecipients to ensure compliance with federal program requirement, review financial and performance reports submitted by subrecipients, and ensure that subaward expenditures are supported and allowable before including them in reimbursement requests to the pass-through entity. Under 2 CFR 200.302(b) and 2 CFR 200.403(g), non-federal entities must maintain adequate documentation to support all costs charged to federal awards, including amounts reimbursed through subaward arrangements. Statement of Condition: During our testing over the subrecipient monitoring compliance requirement, we noted that although the Company was able to provide documentation supporting certain subaward expenditures, the Company was unable to provide documentation that reconciled or agreed to the specific amounts submitted to RIDOH for reimbursement. As a result, we were unable to verify that the subaward expenditures included in the reimbursement requests were fully supported by underlying subrecipient records and that they were appropriately monitored prior to submission. Cause of Condition: The entity did not maintain documentation of internal control activities beyond the minimum required retention period and did not have processes in place to preserve institutional knowledge during employee turnover. As a result, supporting records necessary for compliance over subrecipient monitoring of federal awards were no longer available. Effect of Condition: Because the support for subaward expenditures did not agree to the amounts submitted to RIDOH the Company is not in compliance with subrecipient monitoring requirements under Uniform Guidance, there is an increased risk that unallowable, inaccurate, or unsupported subrecipient costs may be included in reimbursement requests, RIDOH does not have adequate assurance that the Company performed required oversight of subrecipient financial activity, and unsupported reimbursement amounts may be subject to recovery by the pass-through entity. Questioned Costs: Questioned costs total $127,813, representing the total subawards where documentation of subrecipient monitoring could not be provided. Recommendation: We recommend that management (1) strengthen subrecipient monitoring controls to ensure subrecipient expenditures are reconciled to reimbursement request amounts, (2) implement a standardized reconciliation process and maintain supporting documentation in a centralized location, (3) train staff involved in subrecipient monitoring and reimbursement submissions on Uniform Guidance requirements, and (4) perform periodic internal reviews to ensure compliance and documentation completeness. Identification of Repeat Finding: This is a new finding. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.
2019-004 Allowable Costs Federal Program: Aging Cluster – 93.044/93.045/93.053 Criteria: Per 7 CFR Section 200.302 (b)(4) the Organization is required to maintain 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. Condition: During our testing, we noted 2 instances out of 18 where expenses did not have proper approval on invoices. Questioned Costs: None Context: 18 expenses were selected during 2019 and we noted 2 instances of noncompliance. The sample is a statistically valid sample. Effect: An ineffective control system related to the review and approval of grant expenses. Repeat finding: This is not a repeat finding. Recommendation: The Organization should implement the appropriate controls to ensure all expenses are individually reviewed and approved by appropriate personnel. Views of responsible officials and planned corrective actions: The Finance & Administrative Director will implement an electronic workflow for expense review and approval by staff, supervisors, and directors as necessary. The process will be approved by the President & CEO.
2019-005 Matching Federal Program: Aging Cluster – 93.044/93.045/93.053 Criteria: Per 7 CFR Section 200.302 (b)(4) the Organization is required to maintain 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. Condition: During our testing, we noted of the 3 months tested that the volunteer sign-in sheets tested were not properly approved. Questioned Costs: None Context: Volunteer forms were completed by the volunteers but did not have proper approval by on-site supervisory personnel. Effect: An ineffective control system related to the review and approval of volunteer sign-in sheets. Repeat finding: This is not a repeat finding. Recommendation: We recommend the Organization implement a procedure to ensure all volunteer sign-in sheets are approved. Views of responsible officials and planned corrective actions: The Finance & Administrative Director will implement a new procedure to ensure all volunteer sign-in sheets are approved by the staff, supervisors, and directors at each location when submitted. An “Approved By” line will be included on all sheets.