2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that four in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. The Treasurer reviewed the claim after the submission when the money was received. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that four in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. The Treasurer reviewed the claim after the submission when the money was received. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that four in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. The Treasurer reviewed the claim after the submission when the money was received. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: We noted that four in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. The Treasurer reviewed the claim after the submission when the money was received. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation implement a documented, formal review of the claims before they are submitted for reimbursement. Views of Responsible Officials and Planned Corrective Actions: For the views of the responsible officials, refer to the Corrective Action Plan that is part of this report.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 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. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Emergency Rental Assistance Program Federal Financial Assistance Listing Number: 21.023 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.01 of the Uniform Guidance states that the County may report charges on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instance where reports were prepared on the cash basis, but reports indicated that the costs were reported on the accrual basis of accounting: ? Two (2) out of the three (3) reports for the HCA. Corrective action of prior year finding was implemented mid-year. Cause: The HCA department reported amounts on cash basis, but the form identified the basis for the report as ?accrual?. The HCA department review process and certification of the report did not identify the discrepancy. Effect: The County?s control was not consistently followed, which applies the basis of accounting on a consistent basis. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) reports were selected for report testing. Repeat Finding from Prior Years: Yes, Finding 2021-005. Recommendation: We recommend the HCA adhere to their policies and apply the same basis of accounting on a consistent basis for the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.
FINDING 2022-002, 2021-001 ? REPEAT FINDING Information on the Federal Program: Federal Agencies: U.S. Department of Education Federal Programs: 84.027/84.173 Special Education Cluster (IDEA) 84.377 School Improvement Grants (Title 1003a IL-Empower) 93.323 Epidemiology and Lab Capacity (ELC) Pass-Through Entity: Illinois State Board of Education; City of Chicago Department of Public Health (CDPH) Pass-Through Entity Award Numbers: H027A210072; S377A160014 Criteria: Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Sections 200.318 through Section 200.327. A. Section 200.320 identifies five methods of procurement to be followed: a. Informal ? micro-purchases b. Informal ? small purchases c. Formal ? sealed bids d. Formal ? competitive proposals e. Noncompetitive proposals Section 200.318 states that non-federal entities must have and use documented procurement procedures that are consistent with State and local laws in addition to the requirements of the Uniform Guidance. B. Per Section 200.320(b) if small purchases are used, price or rate quotations must be obtained from an adequate number of qualified sources. C. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? D. The Chicago Public Schools Procurement Manual requires the collection of three quotes for any purchase between $2,000.01 and $25,000 for any purchase with federal grant funds. Condition/Context: For the three programs referenced, we tested one-hundred and five (105) purchase orders totaling $31,156,308. Thirty-four (34) purchase orders totaling $523,384 were purchases greater than $2,000 but less than $25,000, and for which CPS did not obtain and/or document an adequate number of price or rate quotations as required by CPS? procurement policies. Our samples were not statistically valid. Cause: CPS employees at the program/school level may not be following the CPS Procurement Manual due to the decentralized nature of the process and the high number of purchases that can fall under the $2,000.01-$25,000 threshold. Questioned Costs: Questioned costs, if any, are unable to be determined, however, actual purchase orders that did not comply with the small purchase requirements of the CPS Policy Manual totaled $133,788 for Assistance Listing Number 84.027/84.173, $376,459 for Assistance Listing Number 84.377, and $13,137 for Assistance Listing Number 93.323. Effect: Chicago Public Schools did not document compliance with the requirements of the CPS Policy Manual as it relates to small purchases that fall between $2,000.01 and $25,000. Recommendation: We recommend that CPS communicate and re-enforce its procurement policies and procedures and any changes thereto in order to comply with the purchase requirements of the CPS Procurement Manual. Ensure proper communication is delivered to relevant employees regarding any changes to the CPS Procurement Manual and the CPS Procurement Manual. In addition, we recommend the consideration of implementing a system control that requires the recording of three quotes for purchases between $2,000.01 and $25,000. The system may be the permanent record. Views of Responsible Officials: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed.