Reference Number: 2022-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Medical Loss Ratio Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For all contracts, the state must ensure that each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP), and Prepaid Ambulatory Health Plan (PAHP) submits a report with the data elements specified in 42 CFR sections 438.8(k) and 438.8(n). The report should contain the required 13 data elements in the regulation, reflect the correct reporting years, and contain an attestation of accuracy regarding the calculation of the medical loss ratio. Managed care plans are required to submit the annual report in the time and manner established by the state, which must be within 12 months after the end of the MLR reporting year. The state should have a policy and procedure to indicate when the report(s) are due from plans and should not accept multiple submissions from plans unless the capitation payments are revised retroactively. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Documentation to support the Medical Loss Ratio (MLR) reports for one of the state?s MCOs was not readily available for review. States are required to develop and implement internal controls to ensure proper supporting documentation is maintained. More than two months elapsed before the Division was able to provide adequate support for a sample of MLR reports selected for testing. Context: Four reports were required for the two managed care organization providers within the state for the MLR 12-month period ended 12/31/2021. Supporting documentation for two of these reports were not submitted for audit review in a timely manner. Questioned costs: None noted. Cause: The Division?s procedures and controls are not sufficient to ensure timely submission of requested audit documentation. Effect: Lack of timely review and effective controls could cause the Division to be out of compliance with MLR reporting requirements. Recommendation: The Division should review and enhance its procedures and controls regarding MLR reporting to ensure that supporting documentation is readily available upon audit request. Views of responsible officials: The Division will review internal controls and archiving process to ensure all required MLR reporting support documentation is provided in a timely manner during the audit.
Reference Number: 2022-020 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Managed Care Financial Audit Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: The state must periodically, but no less frequently than once every three years, conduct, or contract for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of each managed care organization (MCO) and post the results of these audits on its website (42 CFR section 438.602(e)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not conduct or contract for independent audits of its managed care providers within the last three years and as such, results were not posted to their website. Context: For the two managed care providers within the state, the Division did not conduct or contract for the independent audits during the fiscal year under audit or within the last three years. Questioned costs: None noted. Cause: The Division does not have sufficient procedures in place to ensure that independent audits are conducted for its managed care providers at least once every three years. Effect: The Division is unable to verify the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO as required by the program. Recommendation: The Division should implement procedures to ensure that it conducts or contracts for independent audits of its managed care providers at least once every three years and posts the results of those audits to their website. Views of responsible officials: The Division will develop a process to ensure the contracted MCO?s have received an independent audit as required and that the results of that audit are posted to the website. In addition, the Division will also utilize our independent Actuary CPA to review the financial data of MCO?s as an additional step in the review process.
Reference Number: 2022-021 Prior Year Finding: 2021-015 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Provider Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: In order to receive Medicaid payments, providers must: (1) be licensed in accordance with federal, state, and local laws and regulations to participate in the Medicaid program (42 CFR sections 431.107 and 447.10; and Section 1902(a)(9) of the Social Security Act (42 USC 1396a(a)(9)); (2) screened and enrolled in accordance with 42 CFR Part 455, Subpart E (sections 455.400 through 455.470); and make certain disclosures to the State (42 CFR part 455, subpart B, sections 455.100 through 455.106). Medicaid managed care network providers are subject to the same disclosure, screening, enrollment, and termination requirements that apply to Medicaid fee-for-service providers in accordance with 42 CFR Part 438, Subpart H. Providers who have been barred from participation by the OIG exclusion list are not eligible to be enrolled in the Medicaid program (42 CFR 455.436). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division is not in compliance with federal regulations relating to provider eligibility requirements for both new and revalidated providers. Context: The following exceptions were noted during testing of provider eligibility requirements: ? For 40 of 60 providers, no documentation was available to support that the provider was properly licensed or screened and enrolled in accordance with federal requirements. A license was not provided or the license provided was expired. The provider was not properly screened and enrolled in accordance with 42 CFR Part 455, Subpart E; specifically, no agreements on file, applications outdated, or the provider was not revalidated within the last five years. ? For the same 20 of 60 providers, documentation was not available to support that the provider made all required disclosures to the State in accordance with 2 CFR Part 455, Subpart B. ? For 20 of 60 providers, no documentation was available to support that the Division ensured the provider was not on the OIG?s exclusion list at the time services were provided. Questioned costs: Undetermined, based on lack of information, we were unable to determine if unallowed costs were incurred. Cause: The Division did not consistently follow procedures to determine and monitor provider eligibility. Effect: The Division was unable to support provider eligibility which may result in unallowed costs. Recommendation: The Division should reevaluate its current process and perform additional training for determining and monitoring provider eligibility. More thorough reviews and supervision should be placed around the provider eligibility processes. Views of responsible officials: The Division is reevaluating the current process for validating non-Par provider eligibility. Developing additional training for determining and monitoring provider eligibility are under examination as we search for best practices. Completing more thorough reviews and increased supervisory oversight around the provider eligibility processes are a priority.
Reference Number: 2022-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Medical Loss Ratio Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For all contracts, the state must ensure that each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP), and Prepaid Ambulatory Health Plan (PAHP) submits a report with the data elements specified in 42 CFR sections 438.8(k) and 438.8(n). The report should contain the required 13 data elements in the regulation, reflect the correct reporting years, and contain an attestation of accuracy regarding the calculation of the medical loss ratio. Managed care plans are required to submit the annual report in the time and manner established by the state, which must be within 12 months after the end of the MLR reporting year. The state should have a policy and procedure to indicate when the report(s) are due from plans and should not accept multiple submissions from plans unless the capitation payments are revised retroactively. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Documentation to support the Medical Loss Ratio (MLR) reports for one of the state?s MCOs was not readily available for review. States are required to develop and implement internal controls to ensure proper supporting documentation is maintained. More than two months elapsed before the Division was able to provide adequate support for a sample of MLR reports selected for testing. Context: Four reports were required for the two managed care organization providers within the state for the MLR 12-month period ended 12/31/2021. Supporting documentation for two of these reports were not submitted for audit review in a timely manner. Questioned costs: None noted. Cause: The Division?s procedures and controls are not sufficient to ensure timely submission of requested audit documentation. Effect: Lack of timely review and effective controls could cause the Division to be out of compliance with MLR reporting requirements. Recommendation: The Division should review and enhance its procedures and controls regarding MLR reporting to ensure that supporting documentation is readily available upon audit request. Views of responsible officials: The Division will review internal controls and archiving process to ensure all required MLR reporting support documentation is provided in a timely manner during the audit.
Reference Number: 2022-020 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Managed Care Financial Audit Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: The state must periodically, but no less frequently than once every three years, conduct, or contract for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of each managed care organization (MCO) and post the results of these audits on its website (42 CFR section 438.602(e)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not conduct or contract for independent audits of its managed care providers within the last three years and as such, results were not posted to their website. Context: For the two managed care providers within the state, the Division did not conduct or contract for the independent audits during the fiscal year under audit or within the last three years. Questioned costs: None noted. Cause: The Division does not have sufficient procedures in place to ensure that independent audits are conducted for its managed care providers at least once every three years. Effect: The Division is unable to verify the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO as required by the program. Recommendation: The Division should implement procedures to ensure that it conducts or contracts for independent audits of its managed care providers at least once every three years and posts the results of those audits to their website. Views of responsible officials: The Division will develop a process to ensure the contracted MCO?s have received an independent audit as required and that the results of that audit are posted to the website. In addition, the Division will also utilize our independent Actuary CPA to review the financial data of MCO?s as an additional step in the review process.
Reference Number: 2022-021 Prior Year Finding: 2021-015 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Provider Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: In order to receive Medicaid payments, providers must: (1) be licensed in accordance with federal, state, and local laws and regulations to participate in the Medicaid program (42 CFR sections 431.107 and 447.10; and Section 1902(a)(9) of the Social Security Act (42 USC 1396a(a)(9)); (2) screened and enrolled in accordance with 42 CFR Part 455, Subpart E (sections 455.400 through 455.470); and make certain disclosures to the State (42 CFR part 455, subpart B, sections 455.100 through 455.106). Medicaid managed care network providers are subject to the same disclosure, screening, enrollment, and termination requirements that apply to Medicaid fee-for-service providers in accordance with 42 CFR Part 438, Subpart H. Providers who have been barred from participation by the OIG exclusion list are not eligible to be enrolled in the Medicaid program (42 CFR 455.436). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division is not in compliance with federal regulations relating to provider eligibility requirements for both new and revalidated providers. Context: The following exceptions were noted during testing of provider eligibility requirements: ? For 40 of 60 providers, no documentation was available to support that the provider was properly licensed or screened and enrolled in accordance with federal requirements. A license was not provided or the license provided was expired. The provider was not properly screened and enrolled in accordance with 42 CFR Part 455, Subpart E; specifically, no agreements on file, applications outdated, or the provider was not revalidated within the last five years. ? For the same 20 of 60 providers, documentation was not available to support that the provider made all required disclosures to the State in accordance with 2 CFR Part 455, Subpart B. ? For 20 of 60 providers, no documentation was available to support that the Division ensured the provider was not on the OIG?s exclusion list at the time services were provided. Questioned costs: Undetermined, based on lack of information, we were unable to determine if unallowed costs were incurred. Cause: The Division did not consistently follow procedures to determine and monitor provider eligibility. Effect: The Division was unable to support provider eligibility which may result in unallowed costs. Recommendation: The Division should reevaluate its current process and perform additional training for determining and monitoring provider eligibility. More thorough reviews and supervision should be placed around the provider eligibility processes. Views of responsible officials: The Division is reevaluating the current process for validating non-Par provider eligibility. Developing additional training for determining and monitoring provider eligibility are under examination as we search for best practices. Completing more thorough reviews and increased supervisory oversight around the provider eligibility processes are a priority.
Reference Number: 2022-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Medical Loss Ratio Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For all contracts, the state must ensure that each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP), and Prepaid Ambulatory Health Plan (PAHP) submits a report with the data elements specified in 42 CFR sections 438.8(k) and 438.8(n). The report should contain the required 13 data elements in the regulation, reflect the correct reporting years, and contain an attestation of accuracy regarding the calculation of the medical loss ratio. Managed care plans are required to submit the annual report in the time and manner established by the state, which must be within 12 months after the end of the MLR reporting year. The state should have a policy and procedure to indicate when the report(s) are due from plans and should not accept multiple submissions from plans unless the capitation payments are revised retroactively. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Documentation to support the Medical Loss Ratio (MLR) reports for one of the state?s MCOs was not readily available for review. States are required to develop and implement internal controls to ensure proper supporting documentation is maintained. More than two months elapsed before the Division was able to provide adequate support for a sample of MLR reports selected for testing. Context: Four reports were required for the two managed care organization providers within the state for the MLR 12-month period ended 12/31/2021. Supporting documentation for two of these reports were not submitted for audit review in a timely manner. Questioned costs: None noted. Cause: The Division?s procedures and controls are not sufficient to ensure timely submission of requested audit documentation. Effect: Lack of timely review and effective controls could cause the Division to be out of compliance with MLR reporting requirements. Recommendation: The Division should review and enhance its procedures and controls regarding MLR reporting to ensure that supporting documentation is readily available upon audit request. Views of responsible officials: The Division will review internal controls and archiving process to ensure all required MLR reporting support documentation is provided in a timely manner during the audit.
Reference Number: 2022-020 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Managed Care Financial Audit Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: The state must periodically, but no less frequently than once every three years, conduct, or contract for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of each managed care organization (MCO) and post the results of these audits on its website (42 CFR section 438.602(e)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not conduct or contract for independent audits of its managed care providers within the last three years and as such, results were not posted to their website. Context: For the two managed care providers within the state, the Division did not conduct or contract for the independent audits during the fiscal year under audit or within the last three years. Questioned costs: None noted. Cause: The Division does not have sufficient procedures in place to ensure that independent audits are conducted for its managed care providers at least once every three years. Effect: The Division is unable to verify the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO as required by the program. Recommendation: The Division should implement procedures to ensure that it conducts or contracts for independent audits of its managed care providers at least once every three years and posts the results of those audits to their website. Views of responsible officials: The Division will develop a process to ensure the contracted MCO?s have received an independent audit as required and that the results of that audit are posted to the website. In addition, the Division will also utilize our independent Actuary CPA to review the financial data of MCO?s as an additional step in the review process.
Reference Number: 2022-021 Prior Year Finding: 2021-015 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Provider Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: In order to receive Medicaid payments, providers must: (1) be licensed in accordance with federal, state, and local laws and regulations to participate in the Medicaid program (42 CFR sections 431.107 and 447.10; and Section 1902(a)(9) of the Social Security Act (42 USC 1396a(a)(9)); (2) screened and enrolled in accordance with 42 CFR Part 455, Subpart E (sections 455.400 through 455.470); and make certain disclosures to the State (42 CFR part 455, subpart B, sections 455.100 through 455.106). Medicaid managed care network providers are subject to the same disclosure, screening, enrollment, and termination requirements that apply to Medicaid fee-for-service providers in accordance with 42 CFR Part 438, Subpart H. Providers who have been barred from participation by the OIG exclusion list are not eligible to be enrolled in the Medicaid program (42 CFR 455.436). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division is not in compliance with federal regulations relating to provider eligibility requirements for both new and revalidated providers. Context: The following exceptions were noted during testing of provider eligibility requirements: ? For 40 of 60 providers, no documentation was available to support that the provider was properly licensed or screened and enrolled in accordance with federal requirements. A license was not provided or the license provided was expired. The provider was not properly screened and enrolled in accordance with 42 CFR Part 455, Subpart E; specifically, no agreements on file, applications outdated, or the provider was not revalidated within the last five years. ? For the same 20 of 60 providers, documentation was not available to support that the provider made all required disclosures to the State in accordance with 2 CFR Part 455, Subpart B. ? For 20 of 60 providers, no documentation was available to support that the Division ensured the provider was not on the OIG?s exclusion list at the time services were provided. Questioned costs: Undetermined, based on lack of information, we were unable to determine if unallowed costs were incurred. Cause: The Division did not consistently follow procedures to determine and monitor provider eligibility. Effect: The Division was unable to support provider eligibility which may result in unallowed costs. Recommendation: The Division should reevaluate its current process and perform additional training for determining and monitoring provider eligibility. More thorough reviews and supervision should be placed around the provider eligibility processes. Views of responsible officials: The Division is reevaluating the current process for validating non-Par provider eligibility. Developing additional training for determining and monitoring provider eligibility are under examination as we search for best practices. Completing more thorough reviews and increased supervisory oversight around the provider eligibility processes are a priority.
Reference Number: 2022-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Medical Loss Ratio Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For all contracts, the state must ensure that each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP), and Prepaid Ambulatory Health Plan (PAHP) submits a report with the data elements specified in 42 CFR sections 438.8(k) and 438.8(n). The report should contain the required 13 data elements in the regulation, reflect the correct reporting years, and contain an attestation of accuracy regarding the calculation of the medical loss ratio. Managed care plans are required to submit the annual report in the time and manner established by the state, which must be within 12 months after the end of the MLR reporting year. The state should have a policy and procedure to indicate when the report(s) are due from plans and should not accept multiple submissions from plans unless the capitation payments are revised retroactively. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Documentation to support the Medical Loss Ratio (MLR) reports for one of the state?s MCOs was not readily available for review. States are required to develop and implement internal controls to ensure proper supporting documentation is maintained. More than two months elapsed before the Division was able to provide adequate support for a sample of MLR reports selected for testing. Context: Four reports were required for the two managed care organization providers within the state for the MLR 12-month period ended 12/31/2021. Supporting documentation for two of these reports were not submitted for audit review in a timely manner. Questioned costs: None noted. Cause: The Division?s procedures and controls are not sufficient to ensure timely submission of requested audit documentation. Effect: Lack of timely review and effective controls could cause the Division to be out of compliance with MLR reporting requirements. Recommendation: The Division should review and enhance its procedures and controls regarding MLR reporting to ensure that supporting documentation is readily available upon audit request. Views of responsible officials: The Division will review internal controls and archiving process to ensure all required MLR reporting support documentation is provided in a timely manner during the audit.
Reference Number: 2022-020 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Managed Care Financial Audit Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: The state must periodically, but no less frequently than once every three years, conduct, or contract for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of each managed care organization (MCO) and post the results of these audits on its website (42 CFR section 438.602(e)). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not conduct or contract for independent audits of its managed care providers within the last three years and as such, results were not posted to their website. Context: For the two managed care providers within the state, the Division did not conduct or contract for the independent audits during the fiscal year under audit or within the last three years. Questioned costs: None noted. Cause: The Division does not have sufficient procedures in place to ensure that independent audits are conducted for its managed care providers at least once every three years. Effect: The Division is unable to verify the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO as required by the program. Recommendation: The Division should implement procedures to ensure that it conducts or contracts for independent audits of its managed care providers at least once every three years and posts the results of those audits to their website. Views of responsible officials: The Division will develop a process to ensure the contracted MCO?s have received an independent audit as required and that the results of that audit are posted to the website. In addition, the Division will also utilize our independent Actuary CPA to review the financial data of MCO?s as an additional step in the review process.
Reference Number: 2022-021 Prior Year Finding: 2021-015 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program Medicaid Cluster Assistance Listing Number: 93.767, 93.775, 93.777, 93.778 Award Number and Year: 2105DE5021 (10/1/2020 ? 9/30/2022), 2205DE5021 (10/1/2021 ? 9/30/2023) 2105DE5MAP (10/1/2020 ? 9/30/2021), 2205DE5MAP (10/1/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Provider Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: In order to receive Medicaid payments, providers must: (1) be licensed in accordance with federal, state, and local laws and regulations to participate in the Medicaid program (42 CFR sections 431.107 and 447.10; and Section 1902(a)(9) of the Social Security Act (42 USC 1396a(a)(9)); (2) screened and enrolled in accordance with 42 CFR Part 455, Subpart E (sections 455.400 through 455.470); and make certain disclosures to the State (42 CFR part 455, subpart B, sections 455.100 through 455.106). Medicaid managed care network providers are subject to the same disclosure, screening, enrollment, and termination requirements that apply to Medicaid fee-for-service providers in accordance with 42 CFR Part 438, Subpart H. Providers who have been barred from participation by the OIG exclusion list are not eligible to be enrolled in the Medicaid program (42 CFR 455.436). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division is not in compliance with federal regulations relating to provider eligibility requirements for both new and revalidated providers. Context: The following exceptions were noted during testing of provider eligibility requirements: ? For 40 of 60 providers, no documentation was available to support that the provider was properly licensed or screened and enrolled in accordance with federal requirements. A license was not provided or the license provided was expired. The provider was not properly screened and enrolled in accordance with 42 CFR Part 455, Subpart E; specifically, no agreements on file, applications outdated, or the provider was not revalidated within the last five years. ? For the same 20 of 60 providers, documentation was not available to support that the provider made all required disclosures to the State in accordance with 2 CFR Part 455, Subpart B. ? For 20 of 60 providers, no documentation was available to support that the Division ensured the provider was not on the OIG?s exclusion list at the time services were provided. Questioned costs: Undetermined, based on lack of information, we were unable to determine if unallowed costs were incurred. Cause: The Division did not consistently follow procedures to determine and monitor provider eligibility. Effect: The Division was unable to support provider eligibility which may result in unallowed costs. Recommendation: The Division should reevaluate its current process and perform additional training for determining and monitoring provider eligibility. More thorough reviews and supervision should be placed around the provider eligibility processes. Views of responsible officials: The Division is reevaluating the current process for validating non-Par provider eligibility. Developing additional training for determining and monitoring provider eligibility are under examination as we search for best practices. Completing more thorough reviews and increased supervisory oversight around the provider eligibility processes are a priority.
Reference Number: 2022-022 Prior Year Finding: 2021-020 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79TI083305 (9/30/2020 ? 9/29/2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not report required subaward information to FSRS for first-tier subawards of $30,000 or more. Context: Zero of eight subawards selected for testing were reported to FSRS. Total subawards tested were $8,295,312, and $0 was reported as required by FFATA requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Division?s policies and procedures were not sufficient to ensure that required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend that the Division develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Division develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS. Views of responsible officials: The Division will reevaluate its current process, implement proper controls for FFATA reporting standards, and ensure subawards are reviewed timely. In addition, staff will be assigned to verify information prior to being keyed into FSRS.
Reference Number: 2022-023 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79TI083305 (9/30/2020 ? 9/29/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient?s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it monitored its subrecipients. Context: For 4 of 8 subrecipients selected for testing, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Recommendation: The Division should review and enhance internal controls and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient?s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-025 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Condition: The Division did not report required subaward information to FSRS for first-tier subawards of $30,000 or more. Context: Zero of eight subawards selected for testing were reported to FSRS. Total subawards tested were $6,649,227, and $0 was reported as required by FFATA requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Division?s policies and procedures were not sufficient to ensure that required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend that the Division develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Division develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS. Views of responsible officials: The Division will develop internal controls and procedures to ensure that FFATA reporting requirements are met and that information submitted in FSRS is accurate and on time.
Reference Number: 2022-026 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Level of Effort Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per 45 CFR section 96.123(a)(10), the Block Grant shall not be used to supplant State funding of alcohol and other drug prevention and treatment programs. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not meet the program?s level of effort requirements during FY 2022 for Supplement Not Supplant. Context: The State?s requirement for State expenditures during FY 2022 for alcohol and other drug prevention and treatment programs was $30 million and it expended $27 million, for a variance of $3 million. Questioned costs: Undetermined. Cause: The Division did not establish effective procedures and internal controls to ensure that level of effort requirements were met during FY 2022. Effect: The Division was not in compliance with the program?s level of effort requirements for Supplement Not Supplant. The Division expended approximately $3 million less in State funds than was required. Recommendation: The Division should review and enhance procedures and internal controls to ensure that it expends State funds in accordance with level of effort requirements. Views of responsible officials: The Division will review and enhance its procedures and internal controls to ensure that it expends State funds in accordance with level of effort requirements. This review is to include a more detailed procedure for gathering and organizing data from the state?s accounting system. Division program staff believe that this requirement was in fact met; however, the current process documentation is not clear enough to provide the level of support needed for the audit.
Reference Number: 2022-027 Prior Year Finding: 2021-025 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (xi) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (xii) Be incorporated into the official records of the non-Federal entity; (xiii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (xiv) 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; (xv) Comply with the established accounting policies and practices of the non-Federal entity; (ix) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Eight payroll transactions were selected for testing and the following exceptions were noted: ? Four of eight time and effort certifications were not certified and obtained until after the documentation was requested for audit. ? No time and effort certifications were provided for three of eight transactions. Questioned costs: Questioned costs of $2,355 represent the amount of unsupported payroll expenditures charged to the grant. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division will improve the current process through enhanced internal controls and updated training for staff to ensure a clear understanding of the requirements for certification and reporting of time and effort when charged to a federal grant.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient?s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-025 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Condition: The Division did not report required subaward information to FSRS for first-tier subawards of $30,000 or more. Context: Zero of eight subawards selected for testing were reported to FSRS. Total subawards tested were $6,649,227, and $0 was reported as required by FFATA requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Division?s policies and procedures were not sufficient to ensure that required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend that the Division develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the Division develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS. Views of responsible officials: The Division will develop internal controls and procedures to ensure that FFATA reporting requirements are met and that information submitted in FSRS is accurate and on time.
Reference Number: 2022-026 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Level of Effort Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per 45 CFR section 96.123(a)(10), the Block Grant shall not be used to supplant State funding of alcohol and other drug prevention and treatment programs. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not meet the program?s level of effort requirements during FY 2022 for Supplement Not Supplant. Context: The State?s requirement for State expenditures during FY 2022 for alcohol and other drug prevention and treatment programs was $30 million and it expended $27 million, for a variance of $3 million. Questioned costs: Undetermined. Cause: The Division did not establish effective procedures and internal controls to ensure that level of effort requirements were met during FY 2022. Effect: The Division was not in compliance with the program?s level of effort requirements for Supplement Not Supplant. The Division expended approximately $3 million less in State funds than was required. Recommendation: The Division should review and enhance procedures and internal controls to ensure that it expends State funds in accordance with level of effort requirements. Views of responsible officials: The Division will review and enhance its procedures and internal controls to ensure that it expends State funds in accordance with level of effort requirements. This review is to include a more detailed procedure for gathering and organizing data from the state?s accounting system. Division program staff believe that this requirement was in fact met; however, the current process documentation is not clear enough to provide the level of support needed for the audit.
Reference Number: 2022-027 Prior Year Finding: 2021-025 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (xi) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (xii) Be incorporated into the official records of the non-Federal entity; (xiii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (xiv) 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; (xv) Comply with the established accounting policies and practices of the non-Federal entity; (ix) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Time and effort certifications were not certified and obtained timely. Context: Eight payroll transactions were selected for testing and the following exceptions were noted: ? Four of eight time and effort certifications were not certified and obtained until after the documentation was requested for audit. ? No time and effort certifications were provided for three of eight transactions. Questioned costs: Questioned costs of $2,355 represent the amount of unsupported payroll expenditures charged to the grant. Cause: Controls were not operating effectively to ensure that time and effort reporting was performed in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Division should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Division should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Views of responsible officials: The Division will improve the current process through enhanced internal controls and updated training for staff to ensure a clear understanding of the requirements for certification and reporting of time and effort when charged to a federal grant.
Reference Number: 2022-028 Prior Year Finding: No Federal Agency: U.S. Department Homeland Security State Department Name: Department of Safety and Homeland Security, Federal Emergency Management Agency (FEMA) State Division Name: Delaware Emergency Management Agency (DEMA) Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters), COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: 4526-DR-DE (2022), 4566-DR-DE (2022), 4627-DR-DE (2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: DEMA could not produce supporting documentation that it reported required subaward information to FSRS for first-tier subawards of $30,000 or more. Context: DEMA was not able to provide supporting documentation for FSRS reporting for four of five subawards selected for testing. Total subawards tested were $9,839,395, and $229,664 was reported as required by FFATA requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: DEMA?s policies and procedures were not sufficient to ensure that documentation was maintained to support required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: DEMA was unable to provide support that subawards were reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend that DEMA enhance internal controls and procedures to ensure that FFATA reporting requirements are met and supporting documentation for submission is maintained. Views of responsible officials: DEMA finance section has created a group account for FFATA reporting using the group email DEMAFiscal@delaware.gov to enable anyone in that section to access, edit, and submit reports as needed. This will ensure that everyone in the finance section has access to information regardless of turnover. This will also share the workload and assist with timely reporting.
Reference Number: 2022-029 Prior Year Finding: 2021-027 Federal Agency: U.S. Department Homeland Security State Department Name: Department of Safety and Homeland Security, Federal Emergency Management Agency (FEMA) State Division Name: Delaware Emergency Management Agency (DEMA) Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters), COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: 4526-DR-DE (2022), 4566-DR-DE (2022), 4627-DR-DE (2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal Award Identification (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient?s unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: DEMA did not furnish all required information to its subrecipients at the time of issuance of the subawards. Further, DEMA was not able to provide support that it monitored the activities of its subrecipients to ensure that the subawards were used for authorized purposes, nor that it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: ? For five of five subrecipients, the following required information was not provided to the subrecipient at the time of award issuance: Federal Award Identification (FAIN), Federal award date, subaward budget period start and end date, Federal award project description as required by FFATA, name of Federal awarding agency, and Assistance Listing number and title. ? For five of five subrecipients, DEMA was unable to provide support that it monitored the activities of its subrecipients during the fiscal year to ensure that the subawards were used for authorized purposes. ? For three of five subrecipients, DEMA was unable to provide support that it ensured the subrecipients were audited as required by Subpart F. DEMA could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. Questioned costs: Undetermined. Cause: DEMA did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure to detect that subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis. Recommendation: DEMA should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Views of responsible officials: A contractor has been assigned to develop and implement internal controls to ensure all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Subaward letters were updated in September 2022 and a monitoring protocol implemented to begin monitoring all subrecipients to date to include an evaluation of independent audits that is documented as part of the monitoring visit.
Reference Number: 2022-028 Prior Year Finding: No Federal Agency: U.S. Department Homeland Security State Department Name: Department of Safety and Homeland Security, Federal Emergency Management Agency (FEMA) State Division Name: Delaware Emergency Management Agency (DEMA) Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters), COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: 4526-DR-DE (2022), 4566-DR-DE (2022), 4627-DR-DE (2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: DEMA could not produce supporting documentation that it reported required subaward information to FSRS for first-tier subawards of $30,000 or more. Context: DEMA was not able to provide supporting documentation for FSRS reporting for four of five subawards selected for testing. Total subawards tested were $9,839,395, and $229,664 was reported as required by FFATA requirements. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: DEMA?s policies and procedures were not sufficient to ensure that documentation was maintained to support required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: DEMA was unable to provide support that subawards were reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend that DEMA enhance internal controls and procedures to ensure that FFATA reporting requirements are met and supporting documentation for submission is maintained. Views of responsible officials: DEMA finance section has created a group account for FFATA reporting using the group email DEMAFiscal@delaware.gov to enable anyone in that section to access, edit, and submit reports as needed. This will ensure that everyone in the finance section has access to information regardless of turnover. This will also share the workload and assist with timely reporting.
Reference Number: 2022-029 Prior Year Finding: 2021-027 Federal Agency: U.S. Department Homeland Security State Department Name: Department of Safety and Homeland Security, Federal Emergency Management Agency (FEMA) State Division Name: Delaware Emergency Management Agency (DEMA) Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters), COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: 4526-DR-DE (2022), 4566-DR-DE (2022), 4627-DR-DE (2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal Award Identification (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient?s unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: DEMA did not furnish all required information to its subrecipients at the time of issuance of the subawards. Further, DEMA was not able to provide support that it monitored the activities of its subrecipients to ensure that the subawards were used for authorized purposes, nor that it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: ? For five of five subrecipients, the following required information was not provided to the subrecipient at the time of award issuance: Federal Award Identification (FAIN), Federal award date, subaward budget period start and end date, Federal award project description as required by FFATA, name of Federal awarding agency, and Assistance Listing number and title. ? For five of five subrecipients, DEMA was unable to provide support that it monitored the activities of its subrecipients during the fiscal year to ensure that the subawards were used for authorized purposes. ? For three of five subrecipients, DEMA was unable to provide support that it ensured the subrecipients were audited as required by Subpart F. DEMA could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. Questioned costs: Undetermined. Cause: DEMA did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure to detect that subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis. Recommendation: DEMA should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Views of responsible officials: A contractor has been assigned to develop and implement internal controls to ensure all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Subaward letters were updated in September 2022 and a monitoring protocol implemented to begin monitoring all subrecipients to date to include an evaluation of independent audits that is documented as part of the monitoring visit.
Reference Number: 2022-033 Prior Year Finding: 2021-008 Federal Agency: U.S. Department of Education State Department Name: Delaware Technical Community College Federal Program: COVID-19 ? HEERF Student Aid Portion, COVID-19 ? HEERF Institutional Portion Assistance Listing Number: 84.425E, F Award Number and Year: P425E204740 (5/24/2020 ? 6/30/2023) P425F204690 (8/18/2020 ? 6/30/2023) Compliance Requirement: Reporting ? Special Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Recipients of Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) must complete the following special reporting components: 1) Public reporting on the (a)(1) Student Aid Portion; 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) Annual report. Annual Report: All HEERF recipients are required to submit an annual report for the calendar year ending December 31, 2021 no later than May 6, 2022. Quarterly Public Reporting-Student Aid Portion: Institutions must publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Certain line items reported on the 2021 Annual Report and quarterly Student Aid Portion reports filed during FY 2022 by Delaware Technical Community College (the College) did not agree to supporting documentation. In addition, supporting documentation was unavailable for one quarterly Student Aid Portion report. Context: The 2021 Annual Report and two quarterly Student Aid Portion reports were selected for testing. We noted the following exceptions: ? The amount of Emergency Grants reported on the 2021 Annual Report did not agree with supporting documentation. The amount reported was $7,447,850 but supporting documentation was $5,923,898. ? For one of two quarterly Student Aid Portion reports, the College was unable to provide any supporting documentation. Neither documentation of the reporting narrative nor that the report had been posted on the College?s website were available for the report for the quarter ending 12/31/2021. ? For one of two quarterly Student Aid Portion reports, documentation for two key line items did not agree to the amounts reported. Documentation supporting the amount of Emergency Financial Aid Grants distributed to students (Item #3) and the number of students who have received an Emergency Financial aid Grant (Item #5) did not agree to the amounts reported for the quarter ending 9/30/2021. The Student Narrative Report showed $5,797,455 and 635 students vs. $1,139,130.00 and 1422 students on the student ledger. Questioned costs: Undetermined. Cause: The College?s procedures and controls were insufficient to ensure that it maintained documentation supporting the Annual Report and Quarterly Student Aid Portion reports, that it posted reports on its website timely, and that documentation was available for audit. Effect: The College was unable to provide documentation supporting reported information for special reports submitted during FY2022. Recommendation: The College should review and enhance internal controls and procedures to ensure that it maintains documentation supporting the Annual Report and the quarterly student aid portion reports and that this documentation is available for audit. Views of responsible officials: The College?s 2021 Year 2 Annual HEERF-Student Aid report table (Page 3 Table 8a Row 2) was corrected March 24, 2023 and in agreement with Delaware Tech?s student ledger detail (Banner student accounting system extract) when the federal reporting system was open for limited system data entry time. The Year 2 report was corrected and resubmitted as 2022 Year 3 Annual HEERF report filed. Filing is saved for audit review per federal system acceptance communicated. Additional Fiscal Accounting staff have trained to assist the Financial Aid Office with Quarterly HEERF Student Aid Reporting, report posting within 10 days post quarter end, and grant records management for immediate availability. The college continues to review and enhance our HEERF reporting internal controls with reports compiled and confirmed by a team ensuring multiple layers of reconciliation and final system report filing confirmation. Improved data summaries from system extracts with use of website tracking and snapshots at a single point-in-time are in place to support timely reporting and audit verification with the College?s quarterly and cumulative student award disbursement ledger detail. All website update requests will occur via use of the College?s Web Request ticketing system ending with a copy of the site update each quarter.
Reference Number: 2022-033 Prior Year Finding: 2021-008 Federal Agency: U.S. Department of Education State Department Name: Delaware Technical Community College Federal Program: COVID-19 ? HEERF Student Aid Portion, COVID-19 ? HEERF Institutional Portion Assistance Listing Number: 84.425E, F Award Number and Year: P425E204740 (5/24/2020 ? 6/30/2023) P425F204690 (8/18/2020 ? 6/30/2023) Compliance Requirement: Reporting ? Special Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Recipients of Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) must complete the following special reporting components: 1) Public reporting on the (a)(1) Student Aid Portion; 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) Annual report. Annual Report: All HEERF recipients are required to submit an annual report for the calendar year ending December 31, 2021 no later than May 6, 2022. Quarterly Public Reporting-Student Aid Portion: Institutions must publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Certain line items reported on the 2021 Annual Report and quarterly Student Aid Portion reports filed during FY 2022 by Delaware Technical Community College (the College) did not agree to supporting documentation. In addition, supporting documentation was unavailable for one quarterly Student Aid Portion report. Context: The 2021 Annual Report and two quarterly Student Aid Portion reports were selected for testing. We noted the following exceptions: ? The amount of Emergency Grants reported on the 2021 Annual Report did not agree with supporting documentation. The amount reported was $7,447,850 but supporting documentation was $5,923,898. ? For one of two quarterly Student Aid Portion reports, the College was unable to provide any supporting documentation. Neither documentation of the reporting narrative nor that the report had been posted on the College?s website were available for the report for the quarter ending 12/31/2021. ? For one of two quarterly Student Aid Portion reports, documentation for two key line items did not agree to the amounts reported. Documentation supporting the amount of Emergency Financial Aid Grants distributed to students (Item #3) and the number of students who have received an Emergency Financial aid Grant (Item #5) did not agree to the amounts reported for the quarter ending 9/30/2021. The Student Narrative Report showed $5,797,455 and 635 students vs. $1,139,130.00 and 1422 students on the student ledger. Questioned costs: Undetermined. Cause: The College?s procedures and controls were insufficient to ensure that it maintained documentation supporting the Annual Report and Quarterly Student Aid Portion reports, that it posted reports on its website timely, and that documentation was available for audit. Effect: The College was unable to provide documentation supporting reported information for special reports submitted during FY2022. Recommendation: The College should review and enhance internal controls and procedures to ensure that it maintains documentation supporting the Annual Report and the quarterly student aid portion reports and that this documentation is available for audit. Views of responsible officials: The College?s 2021 Year 2 Annual HEERF-Student Aid report table (Page 3 Table 8a Row 2) was corrected March 24, 2023 and in agreement with Delaware Tech?s student ledger detail (Banner student accounting system extract) when the federal reporting system was open for limited system data entry time. The Year 2 report was corrected and resubmitted as 2022 Year 3 Annual HEERF report filed. Filing is saved for audit review per federal system acceptance communicated. Additional Fiscal Accounting staff have trained to assist the Financial Aid Office with Quarterly HEERF Student Aid Reporting, report posting within 10 days post quarter end, and grant records management for immediate availability. The college continues to review and enhance our HEERF reporting internal controls with reports compiled and confirmed by a team ensuring multiple layers of reconciliation and final system report filing confirmation. Improved data summaries from system extracts with use of website tracking and snapshots at a single point-in-time are in place to support timely reporting and audit verification with the College?s quarterly and cumulative student award disbursement ledger detail. All website update requests will occur via use of the College?s Web Request ticketing system ending with a copy of the site update each quarter.
FINDING 2022-001 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Material Weakness Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Certified contractor payrolls related to the construction project were obtained by the School Corporation with no documented review or oversight process in place to ensure their accuracy and compliance. The lack of internal controls was a systemic issue which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed a system of internal controls over the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system places the School Corporation at risk of noncompliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and the Special Tests and Provisions ? Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.
2022-003. Allowable Costs/Cost Principles United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance issued by the U.S. Office of Management and budget requires that salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR ?200.430. Condition: Subpart E, 2 CFR ?200.430 of the Uniform Guidance requires that charges to ?federal awards for salaries and wages must be based on records that accurately reflect the work performed.? The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District failed to prepare periodic certification equivalents correctly, to comply with Subpart E, 2 CFR ?200.430. Cause: Due to turnover in key Business Office positions, the District did not obtain the necessary documentation on a periodic basis to certify that salaries and wages were charged to the appropriate grants. Effect: Noncompliance could result in the incorrect amount of services rendered being charged to the federal award. Questioned Costs: None reported. Context: Total population size of payroll expenditures was 218 for the education stabilization funds, and 44 for the special education cluster. Audit sample size was selected based on small population sampling table, which yielded a sample size of 25 for the education stabilization funds, and 5 for the special education cluster, systematically selected for audit testing. Finding was identified in three audit samples for the education stabilization funds, and two for the special education cluster. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to federal awards in accordance with the requirements of the Uniform Guidance Subpart E, 2 CFR ?200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR ?200.430.
2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. Condition: We noted that for all 25 of the disbursements reviewed, the payments to students were processed after the fifteen calendar day timeframe. Effect: While HEERF funding has been exhausted as of June 30, 2022, not issuing refunds within due dates may impact future federal funding levels for the College. Cause: Issues with communications between the business office and student financial aid department and system issue with the student software caused delays in processing payment to students. Questioned Costs: None. Perspective: Systemic problem noted for all disbursements made to students arising from communication issues between the College?s departments and student software issues. Repeat Finding: No Auditors? Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: See corrective action plan