2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-002: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? Code of Federal Regulation (CFR) ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures incurred and charged to federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Questioned Costs ? $28,787 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 80 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are charged to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials ? Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-003: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of allowable costs and testing of period of performance for expenditures incurred throughout the year, we noted exceptions in the ability of management to support allocations of payroll and nonpayroll expenditures incurred in federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs allocated to the program were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Questioned Costs ? $1,201 Context AL Number: 19.016 We sampled 25 payroll expenditures, totaling $9,560, for Iraq Assistance Programs and noted that two items, totaling $461, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for Iraq Assistance Programs and noted that an additional two items, totaling $211, did not have proper documentation for allocation basis for payroll expenditures charged to the program. AL Number: 19.518 We sampled 25 payroll expenditures, totaling $9,068, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that one item, amounting to $529, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment and allocation is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements requirements. Management has developed a policy in the Iraq local office to aid in time and effort allocation.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-002: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? Code of Federal Regulation (CFR) ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures incurred and charged to federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Questioned Costs ? $28,787 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 80 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are charged to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials ? Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-003: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of allowable costs and testing of period of performance for expenditures incurred throughout the year, we noted exceptions in the ability of management to support allocations of payroll and nonpayroll expenditures incurred in federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs allocated to the program were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Questioned Costs ? $1,201 Context AL Number: 19.016 We sampled 25 payroll expenditures, totaling $9,560, for Iraq Assistance Programs and noted that two items, totaling $461, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for Iraq Assistance Programs and noted that an additional two items, totaling $211, did not have proper documentation for allocation basis for payroll expenditures charged to the program. AL Number: 19.518 We sampled 25 payroll expenditures, totaling $9,068, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that one item, amounting to $529, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment and allocation is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements requirements. Management has developed a policy in the Iraq local office to aid in time and effort allocation.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-006: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions where expenditures were incurred outside of the grant?s performance period. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $125 Context: During our testing of the allowable costs/cost principles compliance requirements, we sampled 25 nonpayroll expenditures, totaling $6,365, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that four items, totaling $125, were incurred and paid outside of the grant award period. Repeat Finding - This finding is a repeat finding from prior year. This finding was reported as finding 2021-001 in the 2021 reporting package. Recommendation - We recommend management revisits and considers revising its internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management is emphasizing prompt period closing to ensure that no items are recorded in the wrong period.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
2022-002: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? Code of Federal Regulation (CFR) ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures incurred and charged to federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Questioned Costs ? $28,787 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 80 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are charged to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials ? Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-003: Internal Control Over Compliance and Compliance with Allowable Costs/Cost Principles Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principle process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Condition ? During our testing of allowable costs and testing of period of performance for expenditures incurred throughout the year, we noted exceptions in the ability of management to support allocations of payroll and nonpayroll expenditures incurred in federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs allocated to the program were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Questioned Costs ? $1,201 Context AL Number: 19.016 We sampled 25 payroll expenditures, totaling $9,560, for Iraq Assistance Programs and noted that two items, totaling $461, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for Iraq Assistance Programs and noted that an additional two items, totaling $211, did not have proper documentation for allocation basis for payroll expenditures charged to the program. AL Number: 19.518 We sampled 25 payroll expenditures, totaling $9,068, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that one item, amounting to $529, did not have proper documentation for allocation basis for the payroll expenditure charged to the program. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of expenditure payment and allocation is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with allowed and allowable requirements requirements. Management has developed a policy in the Iraq local office to aid in time and effort allocation.
2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.
2022-006: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria ? CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions where expenditures were incurred outside of the grant?s performance period. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $125 Context: During our testing of the allowable costs/cost principles compliance requirements, we sampled 25 nonpayroll expenditures, totaling $6,365, for the Overseas Refugee Assistance Program for Western Hemisphere and noted that four items, totaling $125, were incurred and paid outside of the grant award period. Repeat Finding - This finding is a repeat finding from prior year. This finding was reported as finding 2021-001 in the 2021 reporting package. Recommendation - We recommend management revisits and considers revising its internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management is emphasizing prompt period closing to ensure that no items are recorded in the wrong period.
2022-007: Internal Control over Compliance with Reporting Requirements Program: U.S. Department of Housing and Urban Development AL Number: 14.195 AL Name: Section 8 Housing Assistance Payments Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Milwaukee Housing Authority February 4, 2009 through February 4, 2024 City of Milwaukee Housing Authority January 27, 2014 through January 27, 2029 City of Madison Housing Authority June 1, 2016 through May 31, 2031 City of Madison Housing Authority June 20, 2018 through June 20, 2033 Dane County Housing Authority June 1, 2016 through May 29, 2031 Dane County Housing Authority June 20, 2018 through June 20, 2033 Milwaukee County Housing July 15, 2011 through July 15, 2026 Chicago Housing Authority March 1, 2012 through February 28, 2041 Chicago Housing Authority March 1, 2012 through March 31, 2043 Chicago Housing Authority April 1, 2013 through March 31, 2044 Chicago Housing Authority August 27, 2014 through July 31, 2044 Chicago Housing Authority January 1, 2016 through December 31, 2035 Chicago Housing Authority January 9, 2020 through December 31, 2034 Chicago Housing Authority January 23, 2020 through December 31, 2034 Chicago Housing Authority March 1, 2020 through February 28, 2050 Program: U.S. Department of Housing and Urban Development AL Number: 14.249 AL Name: Section 8 Moderate Rehabilitation Single Room Occupancy Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period Chicago Housing Authority March 12, 2020 through March 13, 2022 Chicago Housing Authority December 17, 2020 through December 16, 2022 Program: U.S. Department of Housing and Urban Development AL Number: 14.239 AL Name: Home Investment Partnerships Program Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago April 22, 2019 through April 21, 2034 City of Chicago June 15, 1993 through July 13, 2033 City of Chicago October 3, 2003 through July 2050 Illinois Housing Development Authority January 16, 1997 through January 16, 2027 City of Milwaukee April 17, 2008 through April 21, 2028 City of Milwaukee November 1, 2017 through October 31, 2051 City of Milwaukee August 21, 2020 through August 20, 2040 Program: U.S. Department of Housing and Urban Development AL Number: 14.181 AL Name: Supportive Housing for Persons with Disabilities (Section 811) Grant Award Numbers under the Uniform Guidance Requirements: Pass-Through Entity Award Period City of Chicago January 1, 2003 through January 1, 2043 City of Chicago March 30, 2007 through March 30, 2039 Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Program: U.S. Department of Veterans Affairs AL Number: 64.033 AL Name: VA Supportive Services for Veteran Families Program Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO19CA0226 December 1, 2020 through June 30, 2022 N/A December 1, 2020 through June 30, 2022 N/A February 1, 2021 through September 30, 2022 SPRMCO20CA0209 October 1, 2019 through September 30, 2022 Criteria ? CFR ?200.303 Internal Controls, section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. Condition ? During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure timely submission of required reports to federal funding source. Questioned Costs ? There are no questioned costs as the items outlined above are internal control related matters and not matters related to the accuracy of the information reported to the awarding agency in the financial reports. Effect - Failure to properly track all reporting submission deadlines could lead to delayed funding. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Further, we recommend management implement a policy of formally tracking all required reports and submission deadlines to address the delayed submissions identified above. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis.
Finding Number: 2022-001 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: State of Vermont, Department of Health Program: Immunization - COVID-19 CARES Assistance Listing Number: 93.268 Award Number: 43382 Award Year: 2022 Finding: Internal controls over financial reporting Prior Year Finding: N/A Type of Finding: Material Weakness Criteria In accordance with 2 CFR ?200.303, the non-federal entity must: (1) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (2) Comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal awards. (3) Evaluate and monitor the non-federal entity?s compliance with statutes, regulations, and the terms and conditions of the federal awards. (4) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (5) Take reasonable measures to safeguard protected personally identifiable information and other information the federal awarding agency or pass-through entity designates as sensitive or the non-federal entity considers sensitive consistent with applicable federal, state, local, and tribal laws regarding privacy and responsibility over confidentiality. Condition Management did not have effective internal controls over financial reporting. A large number of material audit adjustments were required, beginning balances were not correct and prior audit entries were not made. The creates a higher risk of material misstatement of federal award expenditures. Cause It appears that this was caused by this the COVID-19 pandemic using up a lot of the Organization?s staff in order to fulfill the services they were required to perform under federal award contracts. Also, this fiscal year being a first-year single audit most likely also contributed to the cause. Effect Poor internal controls over financial reporting create the opportunity for fraud or abuse and can cause the financial statements or the schedule of federal expenditures to be materially misstated. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that the Organization hire an outside consultant to help implement stronger internal controls over financial reporting and to help with the fiscal year end accounting close process. We also recommend that the Organization adopts a formal policy for month and year end accounting. View of Responsible Officials from the Auditee: Management agrees with finding and recommendation. The Organization is going to hire an outside bookkeeper to help with the month end close process. This person will reconcile all bank accounts in a timely manner and help with any accruals that need to be made. The Organization will formulate a comprehensive checklist of all month and year end accounting procedures to ensure that none are missed or overlooked. Also, a depreciation schedule will be kept and updated regularly to help with depreciation journal entries. Management will establish and perform a review process of all of these procedures to ensure they are being done in accordance with company policy.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 19 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for one of three vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation showing full and open competition and detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Additionally, the School Corporation did not obtain a contract for one vendor as required by Indiana Code for purchases between $50,000 and $150,000. As such, the School Corporation did not verify that this vendor was not excluded or disqualified from participation in federal assistance programs or activities. The lack of internal controls and noncompliance related to procurement were isolated to fiscal year 2021-2022. The lack of controls and noncompliance related to suspension and debarment was isolated to the vendor noted above in 2021-2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." INDIANA STATE BOARD OF ACCOUNTS 20 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 19 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for one of three vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation showing full and open competition and detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Additionally, the School Corporation did not obtain a contract for one vendor as required by Indiana Code for purchases between $50,000 and $150,000. As such, the School Corporation did not verify that this vendor was not excluded or disqualified from participation in federal assistance programs or activities. The lack of internal controls and noncompliance related to procurement were isolated to fiscal year 2021-2022. The lack of controls and noncompliance related to suspension and debarment was isolated to the vendor noted above in 2021-2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." INDIANA STATE BOARD OF ACCOUNTS 20 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 19 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for one of three vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the School Corporation did not provide documentation that the threshold had been increased. Documentation showing full and open competition and detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Additionally, the School Corporation did not obtain a contract for one vendor as required by Indiana Code for purchases between $50,000 and $150,000. As such, the School Corporation did not verify that this vendor was not excluded or disqualified from participation in federal assistance programs or activities. The lack of internal controls and noncompliance related to procurement were isolated to fiscal year 2021-2022. The lack of controls and noncompliance related to suspension and debarment was isolated to the vendor noted above in 2021-2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in ?? 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." INDIANA STATE BOARD OF ACCOUNTS 20 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases ? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 21 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system not in place at the school corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. Four construction contracts during the audit period subject to the wage rate requirements; however, none of the contracts had the required prevailing wage rate clause included, nor were certified payrolls submitted by the contractor. The lack of internal controls and sufficient appropriate audit evidence were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 17 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (a) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 18 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system and retain appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls and retain appropriate supporting documentation to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system not in place at the school corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. Four construction contracts during the audit period subject to the wage rate requirements; however, none of the contracts had the required prevailing wage rate clause included, nor were certified payrolls submitted by the contractor. The lack of internal controls and sufficient appropriate audit evidence were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 17 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (a) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 18 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system and retain appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls and retain appropriate supporting documentation to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system not in place at the school corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. Four construction contracts during the audit period subject to the wage rate requirements; however, none of the contracts had the required prevailing wage rate clause included, nor were certified payrolls submitted by the contractor. The lack of internal controls and sufficient appropriate audit evidence were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 17 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (a) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 18 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system and retain appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls and retain appropriate supporting documentation to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system not in place at the school corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. Four construction contracts during the audit period subject to the wage rate requirements; however, none of the contracts had the required prevailing wage rate clause included, nor were certified payrolls submitted by the contractor. The lack of internal controls and sufficient appropriate audit evidence were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 17 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (a) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 18 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system and retain appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls and retain appropriate supporting documentation to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system not in place at the school corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. Four construction contracts during the audit period subject to the wage rate requirements; however, none of the contracts had the required prevailing wage rate clause included, nor were certified payrolls submitted by the contractor. The lack of internal controls and sufficient appropriate audit evidence were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 17 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (a) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 18 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system and retain appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls and retain appropriate supporting documentation to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 15 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation had not implemented internal controls to ensure that capital assets were added to the capital asset ledger. One piece of equipment purchased for $23,346, was not added to the capital asset ledger. Additionally, the asset was not properly maintained or safeguarded. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. . . . (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. . . ." Cause An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 16 RICHMOND COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure compliance and comply with the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
FA 2022-001 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $119,600 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $6,932,136 were expended and reported on the Meriwether County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that a payment was made to the staffing company utilized by the School District to provide bonuses to paraprofessional contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon rates. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the staffing company and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $119,600 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $119,600 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and no deficiencies were noted during the 2022-2023 Federal Review performed by GaDOE. Earlier in the year, a contract amendment had been drawn up to pay for ?retention incentives? to contracted workers, and the staffing company sent correspondence to the School District stating no other addendum was required. The School District was not aware that an additional contract amendment should be initiated prior to the expenditure of funds to pay for an additional bonus payment. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $119,600 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $6,932,136 were expended and reported on the Meriwether County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that a payment was made to the staffing company utilized by the School District to provide bonuses to paraprofessional contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon rates. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the staffing company and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $119,600 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $119,600 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and no deficiencies were noted during the 2022-2023 Federal Review performed by GaDOE. Earlier in the year, a contract amendment had been drawn up to pay for ?retention incentives? to contracted workers, and the staffing company sent correspondence to the School District stating no other addendum was required. The School District was not aware that an additional contract amendment should be initiated prior to the expenditure of funds to pay for an additional bonus payment. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $119,600 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $6,932,136 were expended and reported on the Meriwether County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that a payment was made to the staffing company utilized by the School District to provide bonuses to paraprofessional contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon rates. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the staffing company and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $119,600 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $119,600 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and no deficiencies were noted during the 2022-2023 Federal Review performed by GaDOE. Earlier in the year, a contract amendment had been drawn up to pay for ?retention incentives? to contracted workers, and the staffing company sent correspondence to the School District stating no other addendum was required. The School District was not aware that an additional contract amendment should be initiated prior to the expenditure of funds to pay for an additional bonus payment. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding. FA 2022-001 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $119,600 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $6,932,136 were expended and reported on the Meriwether County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 200.404 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that a payment was made to the staffing company utilized by the School District to provide bonuses to paraprofessional contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing company. Per review of the contract in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon rates. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the staffing company and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $119,600 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $119,600 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and no deficiencies were noted during the 2022-2023 Federal Review performed by GaDOE. Earlier in the year, a contract amendment had been drawn up to pay for ?retention incentives? to contracted workers, and the staffing company sent correspondence to the School District stating no other addendum was required. The School District was not aware that an additional contract amendment should be initiated prior to the expenditure of funds to pay for an additional bonus payment. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
FINDING NO. 2022-001 Federal Program: CFDA 84.063 Federal Pell Grant Program Category: Compliance ? Special tests and provision ? Return of Title IV funds. Criteria: Per 34 CFR Section 668.173(b), returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to U.S. Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.303 also states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our test work over the return of Title IV funds, we noted that in eight cases (8) instances out of a sample of 25 students selected, the Institution returned the funds after the allowable 45 days. Questioned Costs: No questioned costs were identified. Perspective Information: We selected twenty-five (25) students, from the population of withdrawn students during the fiscal year 2021 - 2022. Cause and effect: The return calculation in those cases was performed at the same time that the institution was in the process of reviewing the regulations outlined in the US Department of Education federal notice with an effective date of July 2021 and the usual training made by the institution in these regulatory matters had not yet been carried out. As a result, the federal funds in those cases were not returned timely. Recommendation: The Institution should continue reinforcing the Return of Title IV procedures and establish close coordination between the Student Financial Aid Office and the Register office, in order to improve compliance with federal regulations and avoid a similar situation in the future. Views of Responsible Officials and Planned Corrective Actions: See Institution?s corrective action plan.
Criteria: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: The University did not detect several material noncompliance due to the ineffective internal control over compliance. Questioned Costs: Not applicable
Criteria: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: The University did not detect several material noncompliance due to the ineffective internal control over compliance. Questioned Costs: Not applicable
Criteria: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: The University did not detect several material noncompliance due to the ineffective internal control over compliance. Questioned Costs: Not applicable
FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that two in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that two in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that two in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that two in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing of 20 vouchers for allowability, we noted 1 instance where there the School Corporation was unable to provide the approval of the selected voucher. The School Corporation was able to provide the voucher to support the amount paid and allowability of the voucher. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure all vouchers are properly reviewed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER and GEER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted the amount reported as expended, $0 for ESSER I, on the second report did not agree to the amounts expended per the underlying expenditure records, $28,353 for ESSER I of the School Corporation. Additionally, we noted the for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing of 20 vouchers for allowability, we noted 1 instance where there the School Corporation was unable to provide the approval of the selected voucher. The School Corporation was able to provide the voucher to support the amount paid and allowability of the voucher. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure all vouchers are properly reviewed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER and GEER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted the amount reported as expended, $0 for ESSER I, on the second report did not agree to the amounts expended per the underlying expenditure records, $28,353 for ESSER I of the School Corporation. Additionally, we noted the for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing of 20 vouchers for allowability, we noted 1 instance where there the School Corporation was unable to provide the approval of the selected voucher. The School Corporation was able to provide the voucher to support the amount paid and allowability of the voucher. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure all vouchers are properly reviewed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: Education Stabilization Fund (ESSER) ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER and GEER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted the amount reported as expended, $0 for ESSER I, on the second report did not agree to the amounts expended per the underlying expenditure records, $28,353 for ESSER I of the School Corporation. Additionally, we noted the for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Reference Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Department of Elementary and Secondary Education Federal Program: Child Nutrition Cluster, COVID-19 ? Child Nutrition Cluster Assistance Listing Number: 10.555, 10.559, 10.582 Award Number and Year: 214MA303N1099 (10/1/2020 ? 9/30/2021), 214MA303N1199 (10/1/2020 ? 9/30/2021) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Subrecipient Eligibility - Administering agencies may disburse program funds only to those organizations that meet eligibility requirements under the National School Lunch Program (NSLP), School Breakfast Program (SBP), Special Milk Program for Children (SMP), and Fresh Fruit and Vegetable Program (FFVP). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Department of Elementary and Secondary Education (Department) was unable to provide documentation that its subrecipients met eligibility requirements. Context: The Department documents subrecipient eligibility in a permanent agreement with each subrecipient. For 2 of 40 subrecipients selected for testing, the Department was unable to provide a copy of the approved permanent agreement, therefore, eligibility for these subrecipients could not be verified. Questioned costs: Undetermined. Cause: The Department?s procedures and internal controls were not sufficient to ensure that it retained documentation of subrecipient eligibility. Effect: Failure to verify and maintain documentation of subrecipient eligibility could allow the Commonwealth to issue program payments to subrecipients that are not eligible to receive payments under the program. Recommendation: The Department should enhance its policies and procedures to ensure that it retains copies of permanent agreements where subrecipient eligibility is documented and that this documentation is available for audit. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Department of Elementary and Secondary Education Federal Program: Child Nutrition Cluster, COVID-19 ? Child Nutrition Cluster Assistance Listing Number: 10.555, 10.559, 10.582 Award Number and Year: 214MA303N1099 (10/1/2020 ? 9/30/2021), 214MA303N1199 (10/1/2020 ? 9/30/2021) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Condition: The Department of Elementary and Secondary Education (Department) did not report subaward information to FSRS timely. Context: Twenty-three of forty subrecipients selected for testing were not reported timely to FSRS during FY 2022. The subawards were reported from one to two months later than required by FFATA reporting requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Department?s procedures and controls were not sufficient to ensure that subawards were reported timely to FSRS during FY 2022. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the Department review and enhance procedures and internal controls to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Department of Elementary and Secondary Education Federal Program: Child Nutrition Cluster, COVID-19 ? Child Nutrition Cluster Assistance Listing Number: 10.555, 10.559, 10.582 Award Number and Year: 214MA303N1099 (10/1/2020 ? 9/30/2021), 214MA303N1199 (10/1/2020 ? 9/30/2021) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Subrecipient Eligibility - Administering agencies may disburse program funds only to those organizations that meet eligibility requirements under the National School Lunch Program (NSLP), School Breakfast Program (SBP), Special Milk Program for Children (SMP), and Fresh Fruit and Vegetable Program (FFVP). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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). Condition: The Department of Elementary and Secondary Education (Department) was unable to provide documentation that its subrecipients met eligibility requirements. Context: The Department documents subrecipient eligibility in a permanent agreement with each subrecipient. For 2 of 40 subrecipients selected for testing, the Department was unable to provide a copy of the approved permanent agreement, therefore, eligibility for these subrecipients could not be verified. Questioned costs: Undetermined. Cause: The Department?s procedures and internal controls were not sufficient to ensure that it retained documentation of subrecipient eligibility. Effect: Failure to verify and maintain documentation of subrecipient eligibility could allow the Commonwealth to issue program payments to subrecipients that are not eligible to receive payments under the program. Recommendation: The Department should enhance its policies and procedures to ensure that it retains copies of permanent agreements where subrecipient eligibility is documented and that this documentation is available for audit. Views of responsible officials: Management agrees with the finding.