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.