2 CFR 200 § 200.302

Findings Citing § 200.302

Financial management.

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About this section
Section 200.302 requires states to manage and account for federal awards according to their laws, ensuring financial systems track expenditures and comply with federal regulations. This affects state recipients and subrecipients by mandating accurate reporting and record-keeping for all federal funds received and spent.
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FY End: 2024-06-30
Mountain Area Regional Transit Authority
Compliance Requirement: P
Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compl...

Develop Written Policies and Procedures Criteria: 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award: • Understand and comply with the federal statutes, regulations, and terms and conditions of the award; • Evaluate and monitor compliance; • Take prompt action when instances of noncompliance is identified. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas: 1. Cash Management 2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. 2. Equipment Management Requirements Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e). In addition, the organizations should ensure that existing written procedures are in compliance with: a. General Procurement Standards 2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services. Condition MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls. Effect The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization. Questioned Costs None Recommendation MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed. Views of Responsible Officials and Planned Corrective Action MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA is in the process of updating the Procurement Policy. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2025

FY End: 2024-06-30
Homeless Assistance Leadership Organization, Inc.
Compliance Requirement: A
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management's grant tracking of expenditures for the federal awards was not clearly...

Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Section 200.302 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: Management's grant tracking of expenditures for the federal awards was not clearly classified during the year. Questioned costs: n/a Context: Management was not able to provide a schedule of government grants for a significant period of time after audit fieldwork started. Cause: Due to continued staff turnover, sufficient training for preparing grant tracking spreadsheets is still necessary for new staff and the details of the federal awards received during the year were not clearly defined. At the start of audit fieldwork, it was unknown as to what the actual expenditures for each program were for the year. Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Repeat Finding: Yes. Finding 2023-002. Recommendation: We recommend the Organization provide training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, we recommend reconciliations be performed monthly between the grant spreadsheets and the financial reporting software. A tracking of the federal expenditures needs to be kept and classified to the proper federal and state programs. Views of Responsible Officials: There is no disagreement with the audit finding.

FY End: 2024-06-30
Town of Bridgwater, Vermont
Compliance Requirement: B
2024-004 - Allowable Costs/Cost Principles: Written Financial Policies Federal Program Information: US Department of Agriculture Direct Award ALN: - 10.760 Water and Waste Disposal Systems for Rural Communities Criteria: Per 2 CFR Section 200.302(b)(6), and 200.302(b)(7), a non-federal agency must establish written procedures related to the following: receipt of payment of federal funds and determination of allowability of costs in accordance with Subpart E – Cost Principles, respectively. Condi...

2024-004 - Allowable Costs/Cost Principles: Written Financial Policies Federal Program Information: US Department of Agriculture Direct Award ALN: - 10.760 Water and Waste Disposal Systems for Rural Communities Criteria: Per 2 CFR Section 200.302(b)(6), and 200.302(b)(7), a non-federal agency must establish written procedures related to the following: receipt of payment of federal funds and determination of allowability of costs in accordance with Subpart E – Cost Principles, respectively. Condition: The Town has not formally adopted certain required written financial management policies as outlined in the Code of Federal Regulations. Cause: Town personnel were unaware 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 Town’s written financial policies related to federal compliance and therefore was not the result of a statistical sample. Repeat Finding: This is a repeat finding of 2023-001. Recommendation: The auditor recommends that the Town 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 Town of Bridgewater, Vermont.

FY End: 2024-06-30
Invest in Kids
Compliance Requirement: B
2024-002 Allowable Costs, Subrecipient Reimbursement Coronavirus State & Local Fiscal Recovery Funds – Assistance Listing No. 21.027 – COVID-19 Funding Award Number: 24 QAAA 186913 – Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: The Organization did not have records to adequately support costs reimbursed to a subrecipient for the month of August 2023. Criteria: According to 2 CFR 200....

2024-002 Allowable Costs, Subrecipient Reimbursement Coronavirus State & Local Fiscal Recovery Funds – Assistance Listing No. 21.027 – COVID-19 Funding Award Number: 24 QAAA 186913 – Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: The Organization did not have records to adequately support costs reimbursed to a subrecipient for the month of August 2023. Criteria: According to 2 CFR 200.302(b)(3), The financial management system of each non-Federal entity must provide for the following: (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Additionally, 2 CFR 200.303(a) states 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). Questioned Costs: The total amount reimbursed to the subrecipient for the month of August 2023 of $49,772.27. Cause: The Organization did not obtain source documentation from the sampled subrecipient supporting amounts reimbursed for the month of August 2023. Effect: Costs that are not allowable per the terms and conditions of the grant and/or Uniform Guidance, or improper costs passed through to subrecipients could be charged to the grant. Unallowable or improper costs could be required to be paid back to the Federal awarding agency (and/or pass-through entity). Recommendation: The Organization should strengthen policies and procedures to support a system of internal control regarding review and approval of subrecipient reimbursement requests to ensure costs are backed by source documentation supporting accuracy and allowability prior to payment. Views of Responsible Officials and Planned Corrective Actions: Invest in Kids made multiple requests for source documentation from the subrecipient. However, due to management turnover, the subrecipient lacked personnel with the knowledge to retrieve the requested information. Acknowledging this challenge, Invest in Kids updated its policies and procedures in October 2024. Additionally, all staff participated in the organization's annual financial management and internal controls training that same month. To note, upon completion of this audit, the subrecipient is no longer involved in Invest in Kids programming.

FY End: 2024-06-30
American Indian Community Housing Organization
Compliance Requirement: P
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Org...

Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: Yes Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.

FY End: 2024-06-30
American Indian Community Housing Organization
Compliance Requirement: P
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Org...

Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: Yes Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-2...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-21-DC-41-0001, 2021; B-22-DC-41-0001, 2022; B-23-DC-41-0001, 2023; B-20-DW-41-0001, 2020 (COVID-19); Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302 The department is required under 2 CFR 200.302 to have a financial management system sufficient to permit the preparation of reports required under the terms and conditions of the CDBG grant; and to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Program staff tracked the obligation of grant funds and used this information to prepare the December 31, 2023 PR28 report. However, because of significant turnover in accounting, there was no review from accounting staff to ensure the program tracking reconciled to the State’s financial management application (SFMA). We audited the December 31, 2023 PR28 reports filed for awards from 2020 (including a COVID-19 award), 2021, 2022, and 2023. The expenditures reported in HUD’s Integrated Disbursement and Information System (IDIS) did not materially agree to expenditures or draws recorded in the state’s financial management application (SFMA) for those grants. Variances between cumulative expenditures in SFMA and cumulative expenditures reported ranged between $1.6 million underreported for 2020 to $4.5 million overreported for the 2020 COVID award. In total, cumulative expenditures for those grant awards were overreported by $6.5 million. The CDBG state grants are required to be expended within eight years. Failure to properly account for expenditures for a specific grant year could result in the loss of funds if not obligated and expended within the period of performance of the grant. We recommend the agency reconcile SFMA to amounts in IDIS and make adjustments as necessary to ensure CDBG expenditure reports are accurate and agree to accounting records.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-2...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-21-DC-41-0001, 2021; B-22-DC-41-0001, 2022; B-23-DC-41-0001, 2023; B-20-DW-41-0001, 2020 (COVID-19); Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302 The department is required under 2 CFR 200.302 to have a financial management system sufficient to permit the preparation of reports required under the terms and conditions of the CDBG grant; and to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Program staff tracked the obligation of grant funds and used this information to prepare the December 31, 2023 PR28 report. However, because of significant turnover in accounting, there was no review from accounting staff to ensure the program tracking reconciled to the State’s financial management application (SFMA). We audited the December 31, 2023 PR28 reports filed for awards from 2020 (including a COVID-19 award), 2021, 2022, and 2023. The expenditures reported in HUD’s Integrated Disbursement and Information System (IDIS) did not materially agree to expenditures or draws recorded in the state’s financial management application (SFMA) for those grants. Variances between cumulative expenditures in SFMA and cumulative expenditures reported ranged between $1.6 million underreported for 2020 to $4.5 million overreported for the 2020 COVID award. In total, cumulative expenditures for those grant awards were overreported by $6.5 million. The CDBG state grants are required to be expended within eight years. Failure to properly account for expenditures for a specific grant year could result in the loss of funds if not obligated and expended within the period of performance of the grant. We recommend the agency reconcile SFMA to amounts in IDIS and make adjustments as necessary to ensure CDBG expenditure reports are accurate and agree to accounting records.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-033 Oregon Housing and Community Services Federal reports should contain accurate information Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program Federal Award Numbers and Years: 2302ORLIEI, 2023 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(b)(2); 2 CFR 200.303 Federal regula...

2024-033 Oregon Housing and Community Services Federal reports should contain accurate information Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program Federal Award Numbers and Years: 2302ORLIEI, 2023 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(b)(2); 2 CFR 200.303 Federal regulations require that federal reports are accurate and supported by applicable accounting records. Federal regulations also require management to establish and maintain effective internal control over the federal award. Based on our testing, we identified multiple reports where the amount of obligated funds for the Infrastructure Investment and Jobs Act (IIJA) was not appropriately reported. Funds for this grant were obligated through separate contracts, which differed from the department’s standard process of obligating funds through their grant management system application. At the time these reports were completed, the preparing staff did not have a summary of the IIJA obligations, which resulted in errors in the following September 2023 report line items: • SF-425, Federal Share of Unliquidated Obligations • LIHEAP Performance Data Form, Unobligated Infrastructure Act Funds Carried Over to next FFY • LIHEAP Carryover and Reallotment Report, Carryover Amount • LIHEAP Quarterly Performance and Management Report, Amount of Funds Obligated. Additionally, documentation was not retained to show this report was approved. Based on submitted reports, it appeared the department did not obligate at least 90% of the award by September 30, 2023, as required. However, based on our testing we determined the department had obligated over 90% of the award by September 30, 2023. We recommend department management strengthen internal controls to ensure the required LIHEAP reports contain accurate information.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-2...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-21-DC-41-0001, 2021; B-22-DC-41-0001, 2022; B-23-DC-41-0001, 2023; B-20-DW-41-0001, 2020 (COVID-19); Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302 The department is required under 2 CFR 200.302 to have a financial management system sufficient to permit the preparation of reports required under the terms and conditions of the CDBG grant; and to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Program staff tracked the obligation of grant funds and used this information to prepare the December 31, 2023 PR28 report. However, because of significant turnover in accounting, there was no review from accounting staff to ensure the program tracking reconciled to the State’s financial management application (SFMA). We audited the December 31, 2023 PR28 reports filed for awards from 2020 (including a COVID-19 award), 2021, 2022, and 2023. The expenditures reported in HUD’s Integrated Disbursement and Information System (IDIS) did not materially agree to expenditures or draws recorded in the state’s financial management application (SFMA) for those grants. Variances between cumulative expenditures in SFMA and cumulative expenditures reported ranged between $1.6 million underreported for 2020 to $4.5 million overreported for the 2020 COVID award. In total, cumulative expenditures for those grant awards were overreported by $6.5 million. The CDBG state grants are required to be expended within eight years. Failure to properly account for expenditures for a specific grant year could result in the loss of funds if not obligated and expended within the period of performance of the grant. We recommend the agency reconcile SFMA to amounts in IDIS and make adjustments as necessary to ensure CDBG expenditure reports are accurate and agree to accounting records.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-2...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii (COVID-19) Federal Award Numbers and Years: B-20-DC-41-0001, 2020; B-21-DC-41-0001, 2021; B-22-DC-41-0001, 2022; B-23-DC-41-0001, 2023; B-20-DW-41-0001, 2020 (COVID-19); Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302 The department is required under 2 CFR 200.302 to have a financial management system sufficient to permit the preparation of reports required under the terms and conditions of the CDBG grant; and to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Program staff tracked the obligation of grant funds and used this information to prepare the December 31, 2023 PR28 report. However, because of significant turnover in accounting, there was no review from accounting staff to ensure the program tracking reconciled to the State’s financial management application (SFMA). We audited the December 31, 2023 PR28 reports filed for awards from 2020 (including a COVID-19 award), 2021, 2022, and 2023. The expenditures reported in HUD’s Integrated Disbursement and Information System (IDIS) did not materially agree to expenditures or draws recorded in the state’s financial management application (SFMA) for those grants. Variances between cumulative expenditures in SFMA and cumulative expenditures reported ranged between $1.6 million underreported for 2020 to $4.5 million overreported for the 2020 COVID award. In total, cumulative expenditures for those grant awards were overreported by $6.5 million. The CDBG state grants are required to be expended within eight years. Failure to properly account for expenditures for a specific grant year could result in the loss of funds if not obligated and expended within the period of performance of the grant. We recommend the agency reconcile SFMA to amounts in IDIS and make adjustments as necessary to ensure CDBG expenditure reports are accurate and agree to accounting records.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: L
2024-033 Oregon Housing and Community Services Federal reports should contain accurate information Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program Federal Award Numbers and Years: 2302ORLIEI, 2023 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(b)(2); 2 CFR 200.303 Federal regula...

2024-033 Oregon Housing and Community Services Federal reports should contain accurate information Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program Federal Award Numbers and Years: 2302ORLIEI, 2023 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(b)(2); 2 CFR 200.303 Federal regulations require that federal reports are accurate and supported by applicable accounting records. Federal regulations also require management to establish and maintain effective internal control over the federal award. Based on our testing, we identified multiple reports where the amount of obligated funds for the Infrastructure Investment and Jobs Act (IIJA) was not appropriately reported. Funds for this grant were obligated through separate contracts, which differed from the department’s standard process of obligating funds through their grant management system application. At the time these reports were completed, the preparing staff did not have a summary of the IIJA obligations, which resulted in errors in the following September 2023 report line items: • SF-425, Federal Share of Unliquidated Obligations • LIHEAP Performance Data Form, Unobligated Infrastructure Act Funds Carried Over to next FFY • LIHEAP Carryover and Reallotment Report, Carryover Amount • LIHEAP Quarterly Performance and Management Report, Amount of Funds Obligated. Additionally, documentation was not retained to show this report was approved. Based on submitted reports, it appeared the department did not obligate at least 90% of the award by September 30, 2023, as required. However, based on our testing we determined the department had obligated over 90% of the award by September 30, 2023. We recommend department management strengthen internal controls to ensure the required LIHEAP reports contain accurate information.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Grant County
Compliance Requirement: P
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Que...

2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E. Management’s Progress Toward Prior Year Corrective Action Plan: No progress has been made toward resolving this finding as of June 30, 2024. Criteria Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest: Cash Management (2 CFR §200.302(b)(6)): Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance. Allowable Costs (2 CFR §200.302(b)(7)): Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles. Procurement (2 CFR §200.318(a)): Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds. Cause The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance. Effect The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding. Recommendation The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.

FY End: 2024-06-30
Pyramid Learning Corp.
Compliance Requirement: L
FINDING NO. 2024-001 Federal programs FINANCIAL STATEMENTS All federal financial assistance programs Category Internal control Condition found The Organization accounted for its activities based on the services provided, which are educational services. During our financial and compliance audit procedures for the fiscal year ending June 30, 2024, we noted the following conditions related to the accounting procedures and financial reporting practices of the Organization: a. Accounting and interim ...

FINDING NO. 2024-001 Federal programs FINANCIAL STATEMENTS All federal financial assistance programs Category Internal control Condition found The Organization accounted for its activities based on the services provided, which are educational services. During our financial and compliance audit procedures for the fiscal year ending June 30, 2024, we noted the following conditions related to the accounting procedures and financial reporting practices of the Organization: a. Accounting and interim financial reports are not executed on a current (month-to-month) basis. Accounting journals, general ledger and interim financial reports, such as Balance Sheet, Statement of Activities and Bank Reconciliations, monthly analysis of certain accounts are executed after the end of the related accounting year. Criteria 2 CFR 200.302 (b) (2), (4), (5) and (7) establish that the financial management system of each non Federal entity must provide for the following: i. Cause 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. Contracted outsource for the general accounting of the institution have been unable to prepare the monthly accounting and the related interim financial reports on a current basis. Effect This weakness in the accounting of the institution requires extra efforts from the administration to compensate for the lack of current accountability with additional alternative measures and procedures. Noncompliance with the above-mentioned requirements could lead to administrative actions by the grantor. Questioned Costs NoneIdentification as a Repeated Finding Yes Recommendations The Organization should enforce its policies and procedures in order to accurately maintain its financial information, and on a timely basis, assuring that they reflect its assets and liabilities, and to maintain an appropriate control over its revenues and the amounts expended, which will allow a proper management and monitoring of operations. These policies and procedures should be enforced to consider the following: • Establish monthly and year end closing procedures. • Prepare monthly or quarterly financial reports for management evaluation and analysis. Views of Responsible Officials The Organization agrees with the finding. Executed actions have substantially improved their year-end closing procedures. They contracted a new accounting firm to improve their accounting and the interim financial reporting.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

FY End: 2024-06-30
State of Georgia/state Accounting Office-Ein Noted
Compliance Requirement: AB
2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: ...

2024-038 Noncompliance with Payroll and Travel Expense Policies and Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agencies: Various Pass-Through Entities: Various AL Numbers and Titles: Various – Research and Development Cluster Federal Award Numbers: Various Questioned Costs: None Identified Description: The University did not comply with payroll and travel expense policies and procedures. Background Information: During the year ended June 30, 2024, the Georgia Institute of Technology’s (“GIT” or the “Institute”) Department of Internal Audit completed audits of compliance with payroll and travel expense policies and procedures of two Schools within the Institute and identified noncompliance with those policies and procedures. Criteria: • Uniform Guidance 2 CFR § 200.302 Financial management • Uniform Guidance 2 CFR § 200.308 – Revision of budget and program plans • Uniform Guidance 2 CFR § 200.403 – Factors affecting allowability of costs • Uniform Guidance 2 CFR § 200.404 – Reasonable costs • Uniform Guidance 2 CFR § 200.405 – Allocable costs • Uniform Guidance 2 CFR § 200.430 – Compensation – personal services • Uniform Guidance 2 CFR § 200.475 – Travel costs • Uniform Guidance 2 CFR § 200.432 – Conferences • Title 41 CFR § 301-11.12 • Title 41 CFR § 301-11.200 Subpart C – Reduced per Diem Condition: • Noncompliance with travel policies • Noncompliance with payroll expense policies and procedures Cause: • Lack of sufficient controls for proper review and approval of travel authorizations and expensed transactions associated with sponsored award expenses • Lack of sufficient controls to ensure time and effort is properly charged to sponsored awards • Lack of consistency enforcing payroll expense policies for sponsored award management Effect: Payroll and travel expenditures may not be in compliance with federal or grant award provisions. Recommendation: • Complete and approve spend authorizations before travel to validate the necessity and reasonableness of expenses. • Include detailed justifications in spend authorizations for the travel purpose and award benefit. • Require sufficient justification for payroll expenses charged to sponsored awards, particularly for significant variances in effort. • Update internal control policies to enhance oversight and verification of time and effort reporting. This should include clear guidelines on the documentation required to support the work performed and the consequences of non-compliance. Views of Responsible Officials: Management agrees with the finding. See management’s corrective action plan.

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