Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes.
FA 2022 - 001 Improve Controls over Federal 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 Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $221,797 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 $4,435,698 were expended and reported on the Long 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 services company utilized by the School District to provide bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing services 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 price. Therefore, expenditures totaling $108,960 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. In addition, a review of indirect cost amounts charged to the ESSER fund revealed that the total indirect cost amount budgeted by the School District, which totaled $406,623, was recorded as indirect cost expenditures during the period under review. However, the School District should have applied the indirect cost rate approved by the GaDOE to actual expenditures incurred during the fiscal year to calculate a maximum indirect cost amount of $293,786. Therefore, unallowable indirect costs totaling $112,837 were recorded within the ESSER fund. Questioned Costs: Known questioned costs of $221,797 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 contractor bonuses were allowable as the expenditures were approved by GaDOE through the Consolidated Application process. In addition, management was unaware that indirect costs charged against the program must be based on actual and eligible expenditures incurred rather than the total budgeted amount approved by GaDOE through the Consolidated Application process. 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 and indirect cost amounts are based on actual expenditures rather than budget data. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022 - 001 Improve Controls over Federal 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 Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $221,797 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 $4,435,698 were expended and reported on the Long 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 services company utilized by the School District to provide bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing services 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 price. Therefore, expenditures totaling $108,960 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. In addition, a review of indirect cost amounts charged to the ESSER fund revealed that the total indirect cost amount budgeted by the School District, which totaled $406,623, was recorded as indirect cost expenditures during the period under review. However, the School District should have applied the indirect cost rate approved by the GaDOE to actual expenditures incurred during the fiscal year to calculate a maximum indirect cost amount of $293,786. Therefore, unallowable indirect costs totaling $112,837 were recorded within the ESSER fund. Questioned Costs: Known questioned costs of $221,797 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 contractor bonuses were allowable as the expenditures were approved by GaDOE through the Consolidated Application process. In addition, management was unaware that indirect costs charged against the program must be based on actual and eligible expenditures incurred rather than the total budgeted amount approved by GaDOE through the Consolidated Application process. 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 and indirect cost amounts are based on actual expenditures rather than budget data. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s policies and procedures. Views of Responsible Officials: We concur with this finding.
FA 2022 - 001 Improve Controls over Federal 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 Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $221,797 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 $4,435,698 were expended and reported on the Long 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 services company utilized by the School District to provide bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private staffing services 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 price. Therefore, expenditures totaling $108,960 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. In addition, a review of indirect cost amounts charged to the ESSER fund revealed that the total indirect cost amount budgeted by the School District, which totaled $406,623, was recorded as indirect cost expenditures during the period under review. However, the School District should have applied the indirect cost rate approved by the GaDOE to actual expenditures incurred during the fiscal year to calculate a maximum indirect cost amount of $293,786. Therefore, unallowable indirect costs totaling $112,837 were recorded within the ESSER fund. Questioned Costs: Known questioned costs of $221,797 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 contractor bonuses were allowable as the expenditures were approved by GaDOE through the Consolidated Application process. In addition, management was unaware that indirect costs charged against the program must be based on actual and eligible expenditures incurred rather than the total budgeted amount approved by GaDOE through the Consolidated Application process. 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 and indirect cost amounts are based on actual expenditures rather than budget data. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s policies and procedures. Views of Responsible Officials: We concur with this finding.
Program - Various, including AL 97.036 ? Disaster Grants - Public Assistance (Presidentially Declared Disasters); AL 10.923 ? Emergency Watershed Protection Program; and AL 93.563 ? Child Support Enforcement - Reporting Grant Number & Year - Various Federal Grantor Agency -Various, including U.S. Department of Homeland Security; U.S. Department of Agriculture; and U.S. Department of Health and Human Services Pass-Through Entity -Various, including Nebraska Military Department and Nebraska Department of Health and Human Services Criteria - Title 2 CFR ? 200.510(b) (January 1, 2022) states, in part, the following: The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with ?200.502. Title 2 CFR ? 200.303 (January 1, 2022) states the following, in relevant 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). A good internal control plan requires adequate procedures to ensure the Schedule of Expenditures of Federal Awards (SEFA) is properly presented and includes all Federal expenditures made by the County during the fiscal year. Condition - Colfax County does not have adequate procedures in place to ensure the Schedule of Expenditures of Federal Awards (SEFA) is completed accurately, and includes all Federal expenditures paid by the County. Specifically, we noted that expenditures of $27,831 for Assistance Listing # 10.923 were omitted from the County's fiscal year ending June 30, 2021, SEFA. This was not considered a material error, and it would not have impacted major program determination for the fiscal year 2021 audit. Repeat Finding - No Questioned Costs - None Statistical Sample - No Cause - Administration of Federal awards is decentralized with each County office operating independently without any centralized reporting procedures in place to ensure all Federal expenditures of the County are accurately reported on the SEFA. Additionally, there is an overall lack of knowledge by County personnel related to Federal reporting and compliance requirements. Effect -Increased risk for the SEFA to be inaccurate, which could lead to Federal sanctions or failure to audit programs that should be audited. Recommendation -We recommend the County establish written procedures to ensure the SEFA is complete and accurate. Such procedures may include, among other things, a requirement that all offices in the County responsible for administering a Federal grant report their grant expenditures, and related information, to a single individual in the County with overall responsibility for Federal reporting requirements. That individual should be knowledgeable of Federal reporting and compliance requirements, and review expenditures provided by each office to ensure all amounts are accurate and include all Federal expenditures of the County. View of Officials -The County will develop a Schedule of Expenditures of Federal Awards (SEFA) chart and designate the County Clerk to coordinate the collection of information from individual county offices on Federal awards expenditures.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 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: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Finding No. 2022-001 ? Enrollment reporting Federal Agency: U.S. Department of Education (DOE) Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN: 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition: The University generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 1 student whose change in enrollment status was not timely and accurately transmitted to NSLDS. The University was notified of the student?s enrollment status change from full-time to ?Graduated? in February 2022. Accordingly, the students? status changes should have been transmitted after the semester to report both Campus Level and Program Level enrollment status as ?Graduated.? However, in submitting enrollment information through rosters provided to the NSC, both Campus Level and Program Level statuses were reported as ?Withdrawn.? Questioned Costs: None. Prevalence: Identified in 1 out of 40 students tested. Management evaluated the impacted enrollment roster noting that 64 students ?Graduated? status was not applied and they are improperly reported as ?Withdrawn.? The sample was not intended to be, and was not, a statistically valid sample. Effect: Inaccurate submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. As the University reported these students as withdrawn prior to reporting as graduated, the students loan subsidy and repayments schedules were not impacted. Cause: The University?s internal control processes did not operate consistently to ensure that all enrollment information, including status changes, were submitted accurately to NSLDS. When the February 2022 graduation roster was submitted to the NSC certain records were not applied as there was a mismatch in the information provided. An error file was received by the University, but the corrections were not made. Recommendation: We recommend that the University review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding No. 2022-001 ? Enrollment reporting Federal Agency: U.S. Department of Education (DOE) Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN: 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition: The University generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 1 student whose change in enrollment status was not timely and accurately transmitted to NSLDS. The University was notified of the student?s enrollment status change from full-time to ?Graduated? in February 2022. Accordingly, the students? status changes should have been transmitted after the semester to report both Campus Level and Program Level enrollment status as ?Graduated.? However, in submitting enrollment information through rosters provided to the NSC, both Campus Level and Program Level statuses were reported as ?Withdrawn.? Questioned Costs: None. Prevalence: Identified in 1 out of 40 students tested. Management evaluated the impacted enrollment roster noting that 64 students ?Graduated? status was not applied and they are improperly reported as ?Withdrawn.? The sample was not intended to be, and was not, a statistically valid sample. Effect: Inaccurate submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. As the University reported these students as withdrawn prior to reporting as graduated, the students loan subsidy and repayments schedules were not impacted. Cause: The University?s internal control processes did not operate consistently to ensure that all enrollment information, including status changes, were submitted accurately to NSLDS. When the February 2022 graduation roster was submitted to the NSC certain records were not applied as there was a mismatch in the information provided. An error file was received by the University, but the corrections were not made. Recommendation: We recommend that the University review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding 2022-005. Allowed and Unallowed Costs. (ALN 84.425U ARP ESSER III) CRITERIA: 2 CFR 200.302 requires that a non-federal entity?s financial management systems must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a 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: In our testing of the comparison of actual expenditures to budgeted amounts approved by the Mississippi Department of Education, we noted expenditures for the salaries and benefits for nurses exceeded approved budgeted amounts by $14,417.42. CAUSE: The school district failed to address unfavorable budgetary variances when actual expenditures exceeded approved budgeted amounts. EFFECT: The effect is both a breakdown in budgetary controls and unallowable program costs. Since these excess costs are less than $25,000.00, no costs will be questioned. QUESTIONED COSTS: None RECOMMENDATION: The district should limit expenditures to approved budgeted amounts for this grant. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Section II ? Findings and Questioned Costs ? Financial Statement Findings See schedule of findings and questioned costs included in the Independent Auditors? Report on Internal Control over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards dated January 9, 2023. Section III ? Findings and Questioned Costs ? Major Federal Programs 2022-002 Federal agency: U.S. Department of Health and Human Services Federal program title: Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Reporting period 2 for funds received from July 1, 2020, through December 31, 2020, used through December 31, 2021, and reporting period 3 for funds received from January 1, 2021, through June 30, 2021, used through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Health System did not have documented formal controls and procedures over compliance with federal awards for all expenditures. Condition: The Health System did not have documented formal review processes over the use of the federal awards for all expenditures. Eligible uses of federal awards were tracked in detail and reviewed, with formal approval documented on certain expenditures, but there was not a formal documented review process over whether expenditures were eligible under the federal award in all cases. Questioned Costs: None Context: The Health System maintained detailed records of eligible uses of federal funds for tracking and required reporting purposes. The Health System's Controller and CFO maintained this schedule as eligible uses of funds were identified throughout the organization, reviewed activity, and reconciled the schedule to the general ledger. There was not, however, documentation of a formal review or approval on all expenditures, outside of the schedule being maintained and reconciled. Management did also make regular reports to governance in monthly financial reports, including the use of COVID relief funds and board approval for certain uses of funds. These reports generally covered significant uses of funds and overall status updates on remaining funding, not a comprehensive report of all uses. The Health System does have in place review processes and controls over all expenditures (AP, Payroll), they are just not designed specifically to consider compliance with federal programs. Cause: The Health System has not previously received federal awards in an amount sufficient to require an audit under Uniform Guidance. Therefore, more formal controls and procedures around the use of federal awards had not been in place. The Provider Relief Fund, and certain other federal funds received in response to the COVID-19 pandemic were an unexpected occurrence. As the relief funds were distributed to the Health System, the focus of Health System's management and governance was on responding to the pandemic, and tracking use of related relief funds, and not necessarily on incorporating formal policies and procedures due to the time sensitive nature of the pandemic. In addition, detailed guidance surrounding the Provider Relief Fund was not immediately available and changed quite frequently over the period of the award, making it difficult for organizations to properly incorporate more formal policies and procedures. This finding was also present in the single audit for the year ended June 30, 2021, but due to the timelines of receiving and utilizing the funds and subsequently tracking and reporting them, the Health System did not have adequate time to address this significant deficiency prior to the single audit for the year ended June 30, 2022. Effect: Without formal control and review processes in place over use of federal funds or required reporting under those awards, there is a greater risk of improper use of funds or misstatement in required reporting. Repeat finding: Yes Recommendation: We recommend that management implement more formal control process surrounding the use of federal awards where there is segregation between individuals identifying or proposing expenditures/uses of funds and an individual reviewing and approving that expenditure/use. Documentation of review and approval should be retained in all cases. Views of responsible officials: There is no disagreement with the audit finding.
2022-011: U.S. Department of Education Passed through the State of Nevada Public Charter School Authority Title I Grants to Local Educational Agencies, 84.010 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: 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 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation of the cost to the program. Cause: The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of five reimbursement requests out of a population of 17 was selected for testing. Those five reimbursement requests included 52 transactions out of a population of 138. There was no evidence of review on any of the transactions tested. The 52 transactions totaled $216,914 out of the total aggregate expenditure population of $359,059. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.
2022-012: U.S. Department of Education Passed through the State of Nevada Public Charter School Authority Title I Grants to Local Educational Agencies, 84.010 Level of Effort ? Maintenance of Effort Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: 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 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: The Maintenance of Effort (MOE) calculation submitted to the grantor did not have evidence of review by an individual independent of the preparation of the calculation. Cause: The School did not have adequate internal controls to ensure review of the maintenance of effort occurred or was documented prior to submitting it to the grantor. Effect: Maintenance of Effort information provided to the grantor may not be accurate. Questioned Costs: None noted Context/Sampling: No sampling was performed; the maintenance of effort calculation was tested in its entirety. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of the maintenance of effort occurs and is documented. Views of Responsible Officials: Management agrees with this finding.
2022-011: U.S. Department of Education Passed through the State of Nevada Public Charter School Authority Title I Grants to Local Educational Agencies, 84.010 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: 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 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation of the cost to the program. Cause: The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of five reimbursement requests out of a population of 17 was selected for testing. Those five reimbursement requests included 52 transactions out of a population of 138. There was no evidence of review on any of the transactions tested. The 52 transactions totaled $216,914 out of the total aggregate expenditure population of $359,059. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.
2022-012: U.S. Department of Education Passed through the State of Nevada Public Charter School Authority Title I Grants to Local Educational Agencies, 84.010 Level of Effort ? Maintenance of Effort Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: 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 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: The Maintenance of Effort (MOE) calculation submitted to the grantor did not have evidence of review by an individual independent of the preparation of the calculation. Cause: The School did not have adequate internal controls to ensure review of the maintenance of effort occurred or was documented prior to submitting it to the grantor. Effect: Maintenance of Effort information provided to the grantor may not be accurate. Questioned Costs: None noted Context/Sampling: No sampling was performed; the maintenance of effort calculation was tested in its entirety. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of the maintenance of effort occurs and is documented. Views of Responsible Officials: Management agrees with this finding.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 004 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 21.027 93.323 Federal Award Identification Number and Year: 1505-0271 - 2021 Pass-Through Agency: California Department of Public Health Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.318 General procurement standards of 2 CFR Part 200, the nonfederal 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. According to ? 200.320 Methods of procurement to be followed of 2 CFR Part 200, when the value of the procurement for property or services under a federal financial assistance award exceeds the SAT, or a lower threshold established by a nonfederal entity, formal procurement methods are required. According to ? 180.300 of Subpart C - Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, 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. Criteria or specific requirement (Continued): According to Section 3.4 Formal Solicitations of the County's Purchasing Policy, Purchases of goods and services with an estimated cost of $25,000 or more (including tax, installation, and freight), shall be made as the result of a Formal Solicitation process including but not limited to Invitations for Bids, Requests for Proposals, Requests for Qualifications, Requests for Information and any other formal solicitation method that can be completed within a timeframe that allows for the solicitation, evaluation and approval in accordance with this Section. Formal solicitations may be solicited through Purchasing?s web based system or as otherwise directed by the Purchasing Agent. According to Section 3.5 Exceptions to Competitive Solicitation of the County's Purchasing Policy, in certain circumstances competitive solicitations may not be the most cost-effective approach for procurement. The Board of Supervisors, County Executive, or Purchasing may waive requirements for competitive solicitations in accordance with the grounds permitted by law. Key exemption categories are identified in the Purchasing Policy. Exceptions are not intended to circumvent the competitive process and related County policies and does not eliminate the need to ensure purchases are competitively priced and the terms and conditions of the purchase are in the best interests of the County. A written determination of the basis for the exception to competitive solicitation and the reason for the selection of the particular source shall be included in Purchasing?s records. According to the County's suspension and debarment verification process, prior to entering into an applicable contract or subrecipient agreement, department will verify on SAM.gov if an entity is listed as suspended or debarred. Condition: The County did not follow federal procurement and suspension and debarment regulation nor its purchasing policy and suspension and debarment verification procedures. Questioned costs: Unknown Context: During our testing, we noted the following matters related to procurement and suspension and debarment. Assistance Listing Number 21.027 ? For one of five procurements, the written justification does not contain how the Department knows that there is only one source for the item/service nor the basis upon which the price/cost was determined to be fair and reasonable. Also, no evidence of approval of the sole source procurement in the procurement file. Context (Continued): Assistance Listing Number 21.027 (Continued) ? For three of five procurements, there is no written justification, documentary support, nor evidence of approval of the emergency procurement in the procurement file. ? For two of two procurements, the County did not maintain evidence of the suspension and debarment check before entering into the covered transaction nor evidence of the review and approval of the verification check. ? For one of five procurements, formal procurements are required. However, the County did not use a formal procurement method. Also, no amendment to revise original agreement terms for this contract which reads as a subrecipient relationship rather than a contractor relationship. Assistance Listing Number 93.323 ? For three of five procurements, there is no written justification, documentary support, nor evidence of approval of the sole source procurement in the procurement file. ? For one of five procurements, there is no written justification, documentary support, nor evidence of approval of the emergency procurement in the procurement file. ? For one of five procurements, formal procurements are required. However, the County did not use a formal procurement method rather the County used a personnel recruitment process led by a contracted recruiting firm. ? For five of five procurements, the County did not maintain evidence of the suspension and debarment check before entering into the covered transaction nor evidence of the review and approval of the verification check. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in procurement transactions for the acquisition of property or services required under a federal award not conducted in a manner providing full and open competition and other general procurement standards, as applicable. Also, noncompliance results in procurement transactions with potentially suspended or debarred entities. Recommendation: We recommend the County design controls to ensure compliance with federal procurement and suspension and debarment regulation and its purchasing policy and suspension and debarment verification procedures. We recommend the County develop standard justification forms with approval of the noncompetitive procurement documented on the forms and the forms maintained in the procurement file. Also, we recommend the County update its purchasing policy to ensure clear, concise, and detailed suspension and debarment verification procedures. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 005 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271 - 2021 Award Period: May 26, 2021 - December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to ? 200.302 Financial management of 2 CFR Part 200, the nonfederal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. Further, the financial management system of each nonfederal entity must provide accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our testing, it was noted that the County did not have effective internal controls in place to ensure accurate and complete reporting. Questioned costs: None Context: During our testing, we noted the following matters related to reporting. ? For the interim report, no evidence of review and approval of the report. ? For the Project and Expenditure Report 1, total obligations reported of approximately $907,400. However, the documentation used to prepare the report has an obligated amount of approximately $3,600,000. Thus, a variance of approximately $2,700,000. ? For the Project and Expenditure Report 2, total obligations reported of approximately $3,500,000. However, the documentation used to prepare the report has an obligated amount of approximately $2,800,000. Thus, a variance of approximately $711.900. ? For the Project and Expenditure Report 1 and 2, Subaward No: SBC_01 Period of Performance Start of August 13, 2021. However, the professional services contract has a contract start date of July 13, 2021. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in inaccurate reporting. Recommendation: We recommend the County design controls to ensure review and approval of reports are maintained in the County's grant files. Also, we recommend the County design controls to ensure reports agree to the documentation used to prepare them. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 004 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 21.027 93.323 Federal Award Identification Number and Year: 1505-0271 - 2021 Pass-Through Agency: California Department of Public Health Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.318 General procurement standards of 2 CFR Part 200, the nonfederal 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. According to ? 200.320 Methods of procurement to be followed of 2 CFR Part 200, when the value of the procurement for property or services under a federal financial assistance award exceeds the SAT, or a lower threshold established by a nonfederal entity, formal procurement methods are required. According to ? 180.300 of Subpart C - Responsibilities of Participants Regarding Transactions Doing Business With Other Persons of 2 CFR Part 180, 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. Criteria or specific requirement (Continued): According to Section 3.4 Formal Solicitations of the County's Purchasing Policy, Purchases of goods and services with an estimated cost of $25,000 or more (including tax, installation, and freight), shall be made as the result of a Formal Solicitation process including but not limited to Invitations for Bids, Requests for Proposals, Requests for Qualifications, Requests for Information and any other formal solicitation method that can be completed within a timeframe that allows for the solicitation, evaluation and approval in accordance with this Section. Formal solicitations may be solicited through Purchasing?s web based system or as otherwise directed by the Purchasing Agent. According to Section 3.5 Exceptions to Competitive Solicitation of the County's Purchasing Policy, in certain circumstances competitive solicitations may not be the most cost-effective approach for procurement. The Board of Supervisors, County Executive, or Purchasing may waive requirements for competitive solicitations in accordance with the grounds permitted by law. Key exemption categories are identified in the Purchasing Policy. Exceptions are not intended to circumvent the competitive process and related County policies and does not eliminate the need to ensure purchases are competitively priced and the terms and conditions of the purchase are in the best interests of the County. A written determination of the basis for the exception to competitive solicitation and the reason for the selection of the particular source shall be included in Purchasing?s records. According to the County's suspension and debarment verification process, prior to entering into an applicable contract or subrecipient agreement, department will verify on SAM.gov if an entity is listed as suspended or debarred. Condition: The County did not follow federal procurement and suspension and debarment regulation nor its purchasing policy and suspension and debarment verification procedures. Questioned costs: Unknown Context: During our testing, we noted the following matters related to procurement and suspension and debarment. Assistance Listing Number 21.027 ? For one of five procurements, the written justification does not contain how the Department knows that there is only one source for the item/service nor the basis upon which the price/cost was determined to be fair and reasonable. Also, no evidence of approval of the sole source procurement in the procurement file. Context (Continued): Assistance Listing Number 21.027 (Continued) ? For three of five procurements, there is no written justification, documentary support, nor evidence of approval of the emergency procurement in the procurement file. ? For two of two procurements, the County did not maintain evidence of the suspension and debarment check before entering into the covered transaction nor evidence of the review and approval of the verification check. ? For one of five procurements, formal procurements are required. However, the County did not use a formal procurement method. Also, no amendment to revise original agreement terms for this contract which reads as a subrecipient relationship rather than a contractor relationship. Assistance Listing Number 93.323 ? For three of five procurements, there is no written justification, documentary support, nor evidence of approval of the sole source procurement in the procurement file. ? For one of five procurements, there is no written justification, documentary support, nor evidence of approval of the emergency procurement in the procurement file. ? For one of five procurements, formal procurements are required. However, the County did not use a formal procurement method rather the County used a personnel recruitment process led by a contracted recruiting firm. ? For five of five procurements, the County did not maintain evidence of the suspension and debarment check before entering into the covered transaction nor evidence of the review and approval of the verification check. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in procurement transactions for the acquisition of property or services required under a federal award not conducted in a manner providing full and open competition and other general procurement standards, as applicable. Also, noncompliance results in procurement transactions with potentially suspended or debarred entities. Recommendation: We recommend the County design controls to ensure compliance with federal procurement and suspension and debarment regulation and its purchasing policy and suspension and debarment verification procedures. We recommend the County develop standard justification forms with approval of the noncompetitive procurement documented on the forms and the forms maintained in the procurement file. Also, we recommend the County update its purchasing policy to ensure clear, concise, and detailed suspension and debarment verification procedures. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
FINDING 2022-001 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, After School Snacks, Summer Food Service Program for Children 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 accurate information was presented in order to be in 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 effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $39 of known questioned costs identified. The known questioned costs were calculated taking the number of meals (breakfast, lunch, and snack) overclaimed or underclaimed times the IDOE reimbursement rates for breakfast, lunch and snack for the month tested. The net overclaimed reimbursement amount for the four months tested was $39. Context: We noted that for four claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an effective review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 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, After School Snacks, Summer Food Service Program for Children 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 accurate information was presented in order to be in 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 effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $39 of known questioned costs identified. The known questioned costs were calculated taking the number of meals (breakfast, lunch, and snack) overclaimed or underclaimed times the IDOE reimbursement rates for breakfast, lunch and snack for the month tested. The net overclaimed reimbursement amount for the four months tested was $39. Context: We noted that for four claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an effective review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 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, After School Snacks, Summer Food Service Program for Children 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 accurate information was presented in order to be in 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 effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $39 of known questioned costs identified. The known questioned costs were calculated taking the number of meals (breakfast, lunch, and snack) overclaimed or underclaimed times the IDOE reimbursement rates for breakfast, lunch and snack for the month tested. The net overclaimed reimbursement amount for the four months tested was $39. Context: We noted that for four claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an effective review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 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, After School Snacks, Summer Food Service Program for Children 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 accurate information was presented in order to be in 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 effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $39 of known questioned costs identified. The known questioned costs were calculated taking the number of meals (breakfast, lunch, and snack) overclaimed or underclaimed times the IDOE reimbursement rates for breakfast, lunch and snack for the month tested. The net overclaimed reimbursement amount for the four months tested was $39. Context: We noted that for four claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an effective review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-001 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, After School Snacks, Summer Food Service Program for Children 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 accurate information was presented in order to be in 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 effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $39 of known questioned costs identified. The known questioned costs were calculated taking the number of meals (breakfast, lunch, and snack) overclaimed or underclaimed times the IDOE reimbursement rates for breakfast, lunch and snack for the month tested. The net overclaimed reimbursement amount for the four months tested was $39. Context: We noted that for four claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an effective review control to verify the sponsor claim reimbursement summaries are correct. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. 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: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Criteria: 2 CFR 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented.... " 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed..." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Cause: The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system, as well as to adequately document federal award costs, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Identification as a repeat finding, if applicable: Yes. Identified as finding 2020-002 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Criteria: 2 CFR 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented.... " 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed..." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Cause: The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system, as well as to adequately document federal award costs, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Identification as a repeat finding, if applicable: Yes. Identified as finding 2020-002 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Criteria: 2 CFR 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented.... " 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed..." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Cause: The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system, as well as to adequately document federal award costs, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Identification as a repeat finding, if applicable: Yes. Identified as finding 2020-002 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Criteria: 2 CFR 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented.... " 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed..." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Cause: The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system, as well as to adequately document federal award costs, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Identification as a repeat finding, if applicable: Yes. Identified as finding 2020-002 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Criteria: 2 CFR 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:? (g) Be adequately documented.... " 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed..." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Cause: The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system, as well as to adequately document federal award costs, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Identification as a repeat finding, if applicable: Yes. Identified as finding 2020-002 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number: 2022-001 Repeat Finding: No Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425D Federal Agency: U.S. Department of Education Federal Award Number: S425D210038 Pass-Through Agency: Arizona Department of Education Questioned Costs: $233,091 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Under 2CFR ?200.303, the District is required to establish and maintain effective internal controls over federal awards to provide reasonable assurance that the District is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, section 313(d) of the CRRSA Act and ESEA section 7013(3), 20 U.S.C 7713(3), authorize the use of Education Stabilization Funds for construction activities, including the debt service for such construction activities. CONDITION The District did not ensure that all debt service payments charged to the Education Stabilization Fund were related to construction expenditures incurred. CAUSE The District did not have adequate internal controls in place to ensure that only eligible debt service costs were charged to the program. EFFECT The District charged unallowable costs to the program. CONTEXT During fiscal year 2020-21, the district obtained financing of $1,160,000 to help fund the costs of various building improvements related to indoor air quality and filtration. According to construction invoices on file at the District, $233,091 of the original financing was not utilized on the building improvements and was still available for spending as of fiscal year end 2021-22. During fiscal year 2021-22, the District utilized $1,165,481 of Education Stabilization Funds to pay off the financing agreement, consisting of outstanding principal and accrued interest. As $233,091 of the original financing has yet to be expended, that portion of the debt service payoff is considered an unallowable cost to the program. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Management should review transactions and ensure that program costs are allowable and in adherence to applicable federal requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Reference Number: 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Instance of Noncompliance Criteria Pursuant to the following: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Standards for Financial and Program Management. ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must - Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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). Title 24 ? Housing and Urban Development. Subtitle B - Chapter IX ? Admission to, and Occupancy of, Public Housing. Subpart A ? Applicability, Definitions, Equal Opportunity Requirements ? Section 960.201 ? Eligibility: (1) Basic eligibility. An applicant must meet all eligibility requirements in order to receive housing assistance. At a minimum, the applicant must be a family, and must be income-eligible, as described in this section. Such eligible applicants include single persons. (2) Low income limit. No family other than a low income family is eligible for admission to a Public Housing Authority's (PHA) public housing program. Title 24 ? Housing and Urban Development. Subtitle B - Chapter IX ? Admission to, and Occupancy of, Public Housing. Subpart C ? Rent and Reexamination ? Sections 960.257 and 960.259 ? Family information and verification: (1) For families who pay an income-based rent, the PHA must conduct a reexamination of family income and composition at least annually and must make appropriate adjustments in the rent after consultation with the family and upon verification of the information. The PHA must obtain and document in the family file third-party verification of the following factors, or must document in the file why third-party verification was not available: (1) Reported family annual income; (2) The value of assets; (3) Expenses related to deductions from annual income; and (4) Other factors that affect the determination of adjusted income or income-based rent. Condition and Context During our testing of the eligibility compliance requirements for the Moving to Work (MTW) Demonstration Program (Section 8 Housing Choice Vouchers (HCV) and Low Rent Public Housing (LRPH) programs), we selected tenants from a population of 13,107 HCV tenant cases and 1,454 LRPH tenant cases and identified the following exceptions: HCV (a total of 40 tenant cases selected for testing): ? In four cases, required documentation to establish initial eligibility was missing from the files. The missing documents include copies of social security numbers and evidence of citizenship or eligible immigration status. LRPH (a total of 40 tenant cases selected for testing): ? In nine cases, annual reexaminations that were due were not performed within the required timeframe. ? In four cases, third party evidence supporting the verification of income was missing from the file. ? For nine cases, various documents were missing from the file as evidence to support the initial and recertification of eligibility, including background documents and income Authorization for Release Forms. Cause We noted that the Authority did not have adequate resources assigned to ensure that applicant?s eligibility was properly reviewed and approved prior to acceptance and/or continuance in the Moving to Work Demonstration Program. Effect When the necessary oversight and monitoring of eligibility determinations or recertification is insufficient, the Authority has an increase risk of ineligible participation in the program and individuals receiving improper benefits. Questioned Costs Questioned costs were not identified as the tenants were deemed eligible for the HCV and LRPH programs. Recommendation The Authority should adhere and monitor compliance with its policies to ensure staff and secondary reviews of eligibility applications are performed, while following established guidelines and retaining acceptable documentation to support the eligibility determinations and subsequent recertification. Views of Responsible Officials and Corrective Action Plan Management's response is reported in "Management's Response and Corrective Action Plan" included in a separate section at the end of this report.
Reference Number: 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Instance of Noncompliance Criteria Pursuant to the following: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Standards for Financial and Program Management. ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must - Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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). Title 24 ? Housing and Urban Development. Subtitle B - Chapter IX ? Admission to, and Occupancy of, Public Housing. Subpart A ? Applicability, Definitions, Equal Opportunity Requirements ? Section 960.201 ? Eligibility: (1) Basic eligibility. An applicant must meet all eligibility requirements in order to receive housing assistance. At a minimum, the applicant must be a family, and must be income-eligible, as described in this section. Such eligible applicants include single persons. (2) Low income limit. No family other than a low income family is eligible for admission to a Public Housing Authority's (PHA) public housing program. Title 24 ? Housing and Urban Development. Subtitle B - Chapter IX ? Admission to, and Occupancy of, Public Housing. Subpart C ? Rent and Reexamination ? Sections 960.257 and 960.259 ? Family information and verification: (1) For families who pay an income-based rent, the PHA must conduct a reexamination of family income and composition at least annually and must make appropriate adjustments in the rent after consultation with the family and upon verification of the information. The PHA must obtain and document in the family file third-party verification of the following factors, or must document in the file why third-party verification was not available: (1) Reported family annual income; (2) The value of assets; (3) Expenses related to deductions from annual income; and (4) Other factors that affect the determination of adjusted income or income-based rent. Condition and Context During our testing of the eligibility compliance requirements for the Moving to Work (MTW) Demonstration Program (Section 8 Housing Choice Vouchers (HCV) and Low Rent Public Housing (LRPH) programs), we selected tenants from a population of 13,107 HCV tenant cases and 1,454 LRPH tenant cases and identified the following exceptions: HCV (a total of 40 tenant cases selected for testing): ? In four cases, required documentation to establish initial eligibility was missing from the files. The missing documents include copies of social security numbers and evidence of citizenship or eligible immigration status. LRPH (a total of 40 tenant cases selected for testing): ? In nine cases, annual reexaminations that were due were not performed within the required timeframe. ? In four cases, third party evidence supporting the verification of income was missing from the file. ? For nine cases, various documents were missing from the file as evidence to support the initial and recertification of eligibility, including background documents and income Authorization for Release Forms. Cause We noted that the Authority did not have adequate resources assigned to ensure that applicant?s eligibility was properly reviewed and approved prior to acceptance and/or continuance in the Moving to Work Demonstration Program. Effect When the necessary oversight and monitoring of eligibility determinations or recertification is insufficient, the Authority has an increase risk of ineligible participation in the program and individuals receiving improper benefits. Questioned Costs Questioned costs were not identified as the tenants were deemed eligible for the HCV and LRPH programs. Recommendation The Authority should adhere and monitor compliance with its policies to ensure staff and secondary reviews of eligibility applications are performed, while following established guidelines and retaining acceptable documentation to support the eligibility determinations and subsequent recertification. Views of Responsible Officials and Corrective Action Plan Management's response is reported in "Management's Response and Corrective Action Plan" included in a separate section at the end of this report.
Finding # 2022-002 Program - AL #21.027 ? COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Grant Number & Year - SLFRP2949, FFY 2021 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) ? 200.303 (January 1, 2022) states the following, in relevant 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). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR ? 1000.10 (January 1, 2022), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. The U.S. Department of the Treasury issued ?Compliance and Reporting Guidance? and frequently asked questions, which specify the reporting requirements related to Coronavirus State and Local Fiscal Recovery Funds. Such guidance required the completion of a Project and Expenditure Report by April 30, 2022. A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission. Condition - Lincoln County did not implement effective internal controls to ensure that the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds were completed accurately. Consequently, the Project and Expenditure report submitted on April 29, 2022, did not contain accurate information. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - Lincoln County improperly reported Total Cumulative Expenditures and Total Cumulative Obligations as $6,781,635; however, the correct Total Cumulative Expenditures and Total Cumulative Obligations were $88,754. Additionally, all expenditures were reported under one project, using the project expenditure category of revenue replacement and project expenditure subcategory as provision of government services. Based on the expenditures made by Lincoln County, it appears more appropriate for the County to have reported two projects. The first project provided $83,351 to local non-profit organizations to support their food pantry operations. As such, it appears a project category of negative economic impacts and a project subcategory of aid to nonprofit organizations would be more appropriate. The second project included administrative expenses totaling $5,403. As such, it appears a project category of Administrative and project subcategory of Administrative Expenses would be more appropriate. Cause - Lack of procedures and knowledge relating to Federal reporting requirements Effect - Inaccurate information was reported to the U.S. Department of the Treasury on the April 2022 Project and Expenditure report. Additionally, the County is not in compliance with the reporting requirements set by the U.S Department of the Treasury. Recommendation - We recommend Lincoln County establish written policies and procedures to ensure Federal reporting requirements are completed accurately. Such procedures should include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report. View of Officials - The Lincoln County Board of Commissioners will discuss establishing a policy for reporting requirements. They will also discuss who will file reports for the county going forward and perhaps someone to review the document before submission who is not involved in the preparation of the report.
Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal award in accordance with federal statutes, regulations, and terms and conditions of the awards received. Condition: Management had not established an adequate system of internal control over compliance with the relevant federal statutes, regulations, and terms and conditions of the federal awards as management?s internal control procedures did not cause the entity to retain documentation supporting compliance with the Procurement requirements under the Emergency Connectivity Fund Program and the Special Tests and Provisions requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not retain appropriate documentation to support obtaining price or rate quotations from an adequate number of qualified sources in accordance with 2 CFR section 200.320(b). Management also did not retain appropriate documentation to support compliance with wage rate requirements established under 29 CFR Part 5. Effect or Potential Effect: Without appropriate documentation, non-compliance could occur which the entity may not identify. We were not able to determine if the entity was in compliance with these compliance requirements. Questioned Costs: N/A Recommendation: Management should retain documentation to support proper operation of internal controls over compliance and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Views of Responsible Officials: We are in agreement with the finding and GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Auditor?s Evaluation of the Views of Responsible Officials: Management?s response is appropriate to address the finding. If properly implemented, management?s response would include procedures to prevent reoccurrence in the future.
Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal award in accordance with federal statutes, regulations, and terms and conditions of the awards received. Condition: Management had not established an adequate system of internal control over compliance with the relevant federal statutes, regulations, and terms and conditions of the federal awards as management?s internal control procedures did not cause the entity to retain documentation supporting compliance with the Procurement requirements under the Emergency Connectivity Fund Program and the Special Tests and Provisions requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not retain appropriate documentation to support obtaining price or rate quotations from an adequate number of qualified sources in accordance with 2 CFR section 200.320(b). Management also did not retain appropriate documentation to support compliance with wage rate requirements established under 29 CFR Part 5. Effect or Potential Effect: Without appropriate documentation, non-compliance could occur which the entity may not identify. We were not able to determine if the entity was in compliance with these compliance requirements. Questioned Costs: N/A Recommendation: Management should retain documentation to support proper operation of internal controls over compliance and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Views of Responsible Officials: We are in agreement with the finding and GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Auditor?s Evaluation of the Views of Responsible Officials: Management?s response is appropriate to address the finding. If properly implemented, management?s response would include procedures to prevent reoccurrence in the future.
Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal award in accordance with federal statutes, regulations, and terms and conditions of the awards received. Condition: Management had not established an adequate system of internal control over compliance with the relevant federal statutes, regulations, and terms and conditions of the federal awards as management?s internal control procedures did not cause the entity to retain documentation supporting compliance with the Procurement requirements under the Emergency Connectivity Fund Program and the Special Tests and Provisions requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not retain appropriate documentation to support obtaining price or rate quotations from an adequate number of qualified sources in accordance with 2 CFR section 200.320(b). Management also did not retain appropriate documentation to support compliance with wage rate requirements established under 29 CFR Part 5. Effect or Potential Effect: Without appropriate documentation, non-compliance could occur which the entity may not identify. We were not able to determine if the entity was in compliance with these compliance requirements. Questioned Costs: N/A Recommendation: Management should retain documentation to support proper operation of internal controls over compliance and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Views of Responsible Officials: We are in agreement with the finding and GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Auditor?s Evaluation of the Views of Responsible Officials: Management?s response is appropriate to address the finding. If properly implemented, management?s response would include procedures to prevent reoccurrence in the future.
2022-003 Department of Health and Human Services FFLA #93.087, 90CU0090, 9/30/2020 ? 9/29/2022; 90CU0095, 9/30/2018 ? 9/29/2023 Enhance Safety of Children Affected by Substance Abuse Activities Allowed and Allowable Costs Material Weakness in Internal Control over Compliance Criteria: The Center is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the office records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee?s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: In our sample of expenditures selected for testing, we noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (3 instances). b) Calculation errors for expenses allocated to the grant (4 instances). Cause: Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. Effect: The Center?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. The program was underallocated. Context: A total non-statistical sample of 60 nonpayroll and payroll transactions were tested which accounted for $116,557 out of $870,823 of federal payroll and nonpayroll direct program expenditures. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend management review the procedures and control processes involving timecards and the federal grant expenditure tracking spreadsheet to ensure compliance with the federal grant. Views of Responsible Officials: Management is in agreement.
2022-004 Department of Health and Human Services FFLA #93.087, 90CU0095, 9/30/2018 ? 9/29/2023 Enhance Safety of Children Affected by Substance Abuse Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Through testing of one programmatic report, we noted amounts reported did not agree to supporting documentation. Programmatic information included within the report were included in the wrong category for services provided to adults and children and amounts were included in two categories for services in which no adults or children were provided services. Cause: The preparer of the report improperly inputted the case sizes within the incorrect column within the report and entered incorrect information in two instances. Effect: The report included programmatic information in the wrong categories for services provided and services not provided to adults and children. Questioned Costs: None reported. Context: Included under the award letter of the federal program, one combined quarterly federal cash transaction report was reviewed in the Center?s fiscal year. In addition, one semi-annual federal financial report and one semi-annual programmatic report was reviewed in the Center?s fiscal year. There was a total of 5 reports filed. Repeat Finding from Prior Year: Yes, prior year finding 2021-004 Recommendation: We recommend management review the procedures and control processes surrounding preparation and review of reports to ensure reports are completed based upon supporting documentation. View of Responsible Officials: Management is in agreement.
2022-007 Department of Health and Human Services FFLA #93.087, 90CU0090, 9/30/2020 ? 9/29/2022 Enhance Safety of Children Affected by Substance Abuse FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CRF 200.318 through 200.327 which also requires documentation to be retained to detail the history of procurements. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. Condition: During testing, we identified one contract for each of the above FFLA?s where the required contract provisions in accordance with Uniform Guidance were not included within a contract over $25,000. In addition, no documentation was retained to support management?s rationale to select both of these contracted vendors. Cause: Contract provisions were not evaluated compared to Uniform Guidance contract requirements and documentation was not retained to support management?s rationale to select two contracted vendors. Effect: Contracts may be entered into with a vendor who is suspended or debarred, and contracts may not be in compliance with Uniform Guidance if required contract provisions are not included within the contract. In addition, it is hard to demonstrate that the program complies with laws, regulations, and other compliance requirements when documentation is not retained. Questioned Costs: None reported Context: There was only one contract above the $10,000 procurement policy threshold under the Enhance Safety of Children Affected by Substance Abuse program which was fully tested. There was a total of four contracts above the $10,000 procurement policy threshold under the Section 223 Demonstration Programs to Improve Community Mental Health Services program and two contracts were tested. Repeat Finding from Prior Year: Yes, prior year finding 2021-007 Recommendation: We recommend that management review the procedures and control processes to ensure contract include the required Uniform Guidance provisions and documentation is retained to support the rationale for selecting vendors during the procurement process. Views of Responsible Officials: Management is in agreement.
2022-005 Department of Health and Human Services FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Activities Allowed and Allowable Costs Material Weakness in Internal Control over Compliance Criteria: The Center is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the office records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee?s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: In our sample of expenditures selected for testing, we noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (7 instances). b) Calculation errors for expenses allocated to the grant (2 instances). Cause: Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. Effect: The Center?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. The program was underallocated. Context: A total non-statistical sample of 60 payroll and nonpayroll transactions were tested which accounted for $222,843 out of $2,108,556 of federal payroll and nonpayroll direct program expenditures. Repeat Finding from Prior Year: Yes, prior year finding 2021-005 Recommendation: We recommend management review the procedures and control processes involving timecards and the federal grant expenditure tracking spreadsheet to ensure compliance with the federal grant. Views of Responsible Officials: Management is in agreement.