Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Program: ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN # 84.010 Title I Grants to Local Educational Agencies ALN # 84.181A Special Education-Grants for Infants and Families ALN # 84.365A English Language Acquisition State Grants ALN # 84.367 Supporting Effective Instruction State Grants ALN # 84.425 COVID-19 - Education Stabilization Fund Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022. Questioned Costs – Not applicable. Context – This is a condition identified per review of the School System’s compliance with the specified requirements. Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-003 Significant Deficiency in Internal Controls over Compliance – Reporting Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over submissions of financial reports to comply with terms and conditions of Federal Awards. In addition, the grant awards require timely submission of reports. Additionally, per 2 CFR 200.334 “financial records, supporting documents … and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that quarterly and annual financial reports were accurate, submitted in a timely manner, and supported by expenditures. We noted certain annual reports were not submitted in a timely manner. Additionally, CCS was unable to provide some of the submitted reports that were selected for testing. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department led to a breakdown of established controls and inadequate monitoring of reporting requirements. Effective: CCS was not in compliance with its grant reporting requirements because the reports were submitted late or unable to be provided. Questioned costs: None. Perspective: For AL 93.047, four of twenty-three reports tested were submitted after the required due date. CCS was not able to provide seven of twenty-three reports selected for testing. Regarding the Aging Cluster, CCS was not able to provide three of seven reports selected for testing. For AL 93.558 two of five reports tested were submitted after the required due date. View of responsible officials: Management concurs with this finding. See corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-005 Significant Deficiency in Internal Controls over Compliance – Allowability – Payroll Transactions Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for The Aging – Title III, Part B—Grants For Supportive Services And Senior Centers, Cares Act For Supportive Services Under Title III-B Of The Older Americans Act, And American Rescue Plan For Supportive Services Under Title III-B Of The Older Americans Act AL 93.044 Nutrition Services for Nutrition Services Under Title III-C Of The Older Americans Act, Cares Act For Nutrition Services Under Title III-C Of The Older Americans Act, And American Rescue Plan For Nutrition Services Under Title III-C Of The Older Americans Act AL 93.045 Nutrition Services Incentive Program AL 93.053 Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 Children’s Advocacy Centers AL 93.558 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal control over federal awards that provides reasonable assurance that awards are being managed in compliance with the terms and conditions of the Federal award. Additionally, 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work being performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Internal controls over payroll transactions were not properly designed or implemented to ensure that payroll transactions posted to the accounting system are accurate, allowable, and properly allocated. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of account balances for compliance with requirements. Context: Audit procedures identified the following conditions: • Payroll-related journal entries were not reviewed or approved by an individual other than the preparer prior to posting. • During fiscal year 2022, CCS outsourced payroll services to an external service organization. CCS did not perform reviews or reconciliations of payroll journal entries generated by the external service organization, including entries to record payroll costs allocated to grant awards, prior to posting the payroll entries to the CCS accounting system. • CCS uses multiple allocation pools and the accounting system automatically allocates costs based on system configurations. During fiscal year 2022, CCS had been running the monthly system allocations before all month-end adjustments had been made. Consequently, the allocations were not capturing the system changes to costs that had been made after the allocations had been run. Through substantive procedures, we were able to conclude that costs that were eligible to be allocated to the federal major programs exceeded what was actually allocated and unallowable costs were not identified. Effect: Lack of review or approval of payroll journal entries, system cost pool allocations, and payroll amounts generated by the external payroll service organization could result in inaccurate or unallowable payroll costs charged to grant awards. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that payroll costs charged to federal awards are accurate, allowable, and properly allocated. View of responsible officials: Management concurs with this finding, see corrective action plan.
2022-006 Significant Deficiency in Internal Controls over Compliance – Cash Management Agency: U.S. Department of Health and Human Services Program(s) and Federal Award Identification Number(s): Special Programs for the Aging, Title VI, Part A, Grants to Indian Tribes AL 93.047 New or Repeat: Repeat Criteria: Per 2 CFR 200.303, the non-Federal entity is responsible for maintaining effective internal controls over cash management to comply with terms and conditions of the Federal award. Per CFR 200.305(b), for cost reimbursement awards, the timing of cash draws shall be as close as administratively feasible to the actual disbursements of program costs. Additionally, per 2 CFR 200.334, “financial records, supporting documents . . . and all other non-Federal entity records pertinent to the Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” Condition: Internal controls were not sufficiently designed and implemented to ensure that reimbursement requests were accurate and supported by expenditures incurred prior to the drawdown request. Monthly reimbursement requests were not reviewed by an individual, other than the preparer, to ensure the amount requested agreed to the supporting records. Additionally, the supporting records used to prepare the reimbursement requests were not retained. Reconciliation and monitoring activities were not in place to ensure amounts requested matched recalculated expenditure totals between periods. Cause: Vacancies in key financial positions and lack of adequate resources in the finance department lead to a breakdown of established controls and inadequate monitoring of cash management requirements and documentation. Context: See condition. Effect: Due to the condition of the supporting records and lack of an effective tracking system regarding expenditures already reimbursed, there is potential that CCS could have been reimbursed for the same expense twice or that drawdowns occurred before expenses are incurred. Records had to be recreated in order to complete our audit procedures. Questioned costs: No questioned costs. Recommendation: We recommend management establish policies and procedures to ensure controls are properly designed and implemented to ensure that reimbursement requests are accurate and supported by expenditures incurred. Further, we recommend management develop a tracking spreadsheet to record and monitor monthly reimbursement amounts, as well as the total amount drawndown, over the award’s period of performance. View of responsible officials: Management concurs with this finding, see corrective action plan.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.303 establish 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 200.430 establishes that the cost of compensation for personnel services is allowable to the extent that it follows an appointment made in accordance with the governmental unit's laws and rules and meets the merit system or other requirements required by federal law, where applicable. Compensation for personal services may also include fringe benefits which are addressed in §200.431 Compensation—fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. (i) The Non-Federal entity establishes consistent written policies which apply uniformly to all faculty members, not just those working on Federal awards. Condition a. During our audit, on a sample of sixty (60) personnel files, we observed that the personnel files are not being kept current and in some instances were incomplete. b. One personnel file of federal funds was not provided for our evaluation. c. The PRDH does not have established written policies and manuals which can define standard internal controls for each program and / or region of the entity. Cause PRDH has not established an effective internal control designed to ensure the accuracy and completeness of the employee files. Also, the incompleteness of the files may depend of the time that the employee started working in the agency. Effect Due to law and regulation changes, incomplete files may result in inadequate documentation to support compliance with the criteria over management and administration of personnel files. Also, in the case of employees paid with federal funds, it may result in cost disallowances for personnel that do not meet the requirements to be employed by the corresponding federal program. Questioned Costs None Perspective Information Finding does not represent a significant problem. The Department has addressed this finding and it’s been taking the steps necessary to reduce incidences to a minimum. We selected 60 employee files from all agency. Prior Year Audit Finding 2021-002 Recommendation PRDH should immediately undertake a process to review all personnel files and validate that the minimum requirement documents are appropriately completed and included in each personnel file. Also, the PRDH must update the salary change form in file in order to reflect current salary as stated in the digital information system. Views of Responsible Officials During the month of August, the Office of Human Resources and Labor Relations was audited by the ADA. It is to this that we respond to the findings indicated in the audit, as follows: Over the past few years we have developed an internal control, using a document entitled Check sheet, which contains the list of documents required for the appointment of employees and another for the audit of files. It contains three columns for the collation of documents required by the Analysts of the Appointments and Changes Section and ends with the collation of the Division Supervisor, before being referred to the Personnel Officers of our regions. This document has been modified according to needs, changes, procedures and new regulations. It is important to mention that many of our audited personnel records pertain to employees appointed in years where the required requirements or documents were minimal, and no evidence was required or maintained in the personnel file. Related to the academic preparation contained in the personnel files, they are documents required by the Recruitment and Selection Section and these respond to the minimum requirements and alternatives of the class, according to the Agency's Classification Plan. Each class specification sets minimum requirements for the position the candidate will hold. On the other hand, when the previously known Administration of Health Services Facilities (AFASS) closed in 1999, its employees went to the Department of Health with the file they had, whose procedures and processes were not uniform to those of our Agency. The Regions and Hospitals have delegated the verification of documents, to work on appointments and other personnel transactions, such as job reclassifications, promotions and others. This delegation brings the process of standardizing and authorizing DSP-29 by the Recruitment and Selection Section, to ensure that it is complied with as established in the Classification Plan. The agency is in the process of updating these documents as long as a change in the employee's job classification is applied. These are transactions that allow us to update the employees’ record to the new class they will occupy. In the case of Doping Test results, we mention that these are found in the Medical Record of each employee. By HIPPA law, these are not filed in the personnel file. Of the aspects pointed out in the audit, the Department of Health has developed greater review and audit measures by the analysts of our agency, before the defunct Quality Control Section, who watched over and audited the personnel files of the Regions, providing control and compliance with the documents required according to the Regulations and Standards that govern the Office of Human Resources and Labor Relations. The Office of Human Resources presented a work plan to implement an effective and efficient personnel file review procedure to comply with and improve the agency's personnel processes and transactions. Responsible Officials Lcdo. Luis Rivera Villanueva Sec. Auxiliar de Recursos Humanos 787-765-2929 ext. 4273 Mrs. Luz S. Ramos Pedroza Specialist 787-765-2929 ext. 4273 Mrs. Maribel Zayas Payroll Officer Director 787-765-2929 ext. 4209 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
2022-001 Finding Federal Agency U. S. Department of Education Passed-through Mississippi Department of Education Assistance Listing Number: AL # 84.425 D Program Title: Elementary and Secondary School Emergency Relief II Compliance Requirement: Allowable Cost Repeat Finding from Prior Audit? No Prior Audit Finding Number: N/A Material Weakness Condition: The district requested reimbursement for pre-award COVID related expenditures which were originally paid out of the general fund in the prior fiscal year but failed to reclassify these expenditures to ESSER II funds. Criteria: 2 CFR § 200.303(a) states that a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Under 2 CFR 200.458, an LEA that has not yet received ESSER fund to which it is entitled may use State or local funds to incur allowable cost, and once it receives its ESSER award, reimburse itself for the allowable cost that it incurred before receiving the Federal emergency funds. Cause: The district failed to reclassify pre-award cost in the manner specified by the Mississippi Department of Education once guidance was received instructing district the manner in which to record prior year cost to the ESSER II grant. Effect: Failure to record transactions in the manner prescribed by the Mississippi Department of Education could result in a misstatement of expenditures. An audit adjustment was proposed and made to correct. Recommendation: We recommend the District review its internal control procedures to ensure that internal controls are established and are operating effectively to ensure all costs requested for reimbursement are recorded in the proper grant fund. Views of responsible officials of the auditee: See Auditee’s Corrective Action Plan. Questioned Cost: No known questioned cost.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
2022-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, E, F) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement and suspension and debarment regulation nor its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled five out of five vendors which were paid more than $10,000 in fiscal year 2022, and noted there was no evidence of bids or quotes obtained. Additionally, adequate sole source documentation was not maintained to support the procurement. • We sampled three out of three vendors for tests of internal control over compliance and compliance and we noted Heading Home did not show evidence of internal controls over compliance with suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for the purchase of goods or services in excess of $10,000 three (3) competitive bids must be obtained in writing prior to selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2022) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2022). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provides reasonable assurance Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home is not following their own policies and procedures related to procurement. Additionally, Heading Home’s procurement policy does not note the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with their own policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors and exposed itself to potential liability and loss of federal funds. Recommendation We recommend Heading Home follow their internal control policies and procedures related to procurement, as well as the following: • Document controls to ensure compliance with federal procurement regulation and its federal procurement policy. • Implement policies and procedures to verify the suspension and debarment status of contractors before awarding contracts using federal funds. • Include the required suspension and debarment clause in its contracts with contractors using federal funds. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.
Finding 2022-005 Review of Reporting – Significant Deficiency in Internal Control Over Compliance Agency U.S. Department of Treasury ALN 21.027 Program COVID-19 – Coronavirus Local Fiscal Recovery Fund Award Year FY 2022 Pass-Through Agency State of Alaska Department of Commerce, Community, and Economic Development Pass-Through Entity Identifying Number(s) AK0049 Criteria 2 CFR 200.303, Internal Controls, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition During our testing of the reporting requirements, we noted the one report tested did not have evidence of review before submission. Cause The City’s internal controls over reporting are not designed appropriately to ensure reports required to be submitted to federal agencies are reviewed for accuracy before submission. Effect or potential effect Information submitted to the granting agency may be inaccurate or late. Questioned costs Not applicable. Context During our testwork of the one report required for submission, we identified that the report was submitted timely, but no internal controls were established to document the review and approval of the report before submission. Identification as a repeat finding Not a repeat finding. Recommendation Management should review report due dates and ensure that accurate reports are submitted before they are due. Views of responsible officials Management agrees with the finding. All reporting will be reviewed by at least one other staff member to ensure accuracy prior to submission.
2022-007 – TITLE I – INADEQUATE SUPPORTING DOCUMENTATION– ALN 84.010 – SIGNIFICANT DEFICIENCY & OTHER NONCOMPLIANCE Condition We were unable to verify whether 6 of 60 expenditures totaling $7,591 were for costs allowed under the Title I grant. When projected against the total population of $1,628,283, the total projected error is $15,939. Effect Williston Basin Public School District No. 7 may have charged unallowable expenditures to the grant program. Cause Williston Basin Public School District No. 7 did not maintain support documentation for all expenditures charged to the Title I grant. In addition, there was no evidence of approval on these transactions. Criteria Uniform Guidance 2 CFR 200.303(a) states “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Uniform Guidance 2 CFR 200.403(g) requires costs to be adequately documented. "Standards for Internal Control in the Federal Government" (Green Book) requires management to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. Management is to design appropriate types of control activities for the entity's internal control system. Control activities help management fulfill responsibilities and address identified risk responses in the internal control system. Questioned Costs $7,591 Repeat Finding No. Recommendation We recommend Williston Basin Public School District No. 7 maintain support to ensure all expenditures charged to the Title I grant were approved and were for costs allowed under the grant. Williston Basin Public School District No. 7’s Response See Corrective Action Plan.
Finding 2022-002 – Allowable Costs/Costs Principles and Period of Performance Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN Number: 21.027 Federal Agency: United States Department of the Treasury Federal Award Year: 2022 Grant number: CAPP-PN-2022-05, CA 3010001, and 256399-01 Pass-Through Entity: State of California, Department of Community Services & Development and State Water Resources Control Board Criteria: The State of California (the State) passed through funding to the City of Anaheim (the City) for the California Arrearage Payment Program for electric customers (CAPP) and the California Water and Wastewater Arrearage Payment Program (CWWAPP). Both CAPP and CWWAPP have a provision that required the City to allocate payments to the customer accounts within 60 days of receiving payment from the State. Specifically, per section B, Program Requirements, of the California Water and Wastewater arrearage payment program guidelines, there is a requirement that notes “Water systems that participate in the program must allocate payments as bill credits to customer accounts within 60 days of receiving payment .” Per CAPP Program Notice No. 2022-01, there is a requirement that notes “Within 60 days of receiving CAPP funds, a utility applicant shall issue CAPP assistance benefits to customers as bill credits and include a statement that the credits are a result of California’s CAPP funding.” Additionally, both CAPP and CWWAPP provided for the funds to be utilized for customers arrearages accrued during the COVID-19 pandemic bill relief period of March 4, 2020 through June 15, 2021 net of any late fees which are to be waived. CWWAPP provisions are included in Section B Program Requirements and Appendix A, Section 1, Eligibility of the California Water and Wastewater arrearage payment program guidelines. For CAPP the eligibility determinations are included in the 2022 CAPP Frequently Asked Questions. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designated to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are allowable and adhere to the required period of performance. Condition and Context: The City made two disbursements under the CWAPP program for water customers on March 2, 2022 and June 21, 2022. The water funds were received by the City on January 25, 2022. The second disbursement made by the City on June 21, 2022 in the amount of approximately $102,000 was not within the 60-day requirement. The CAPP funds were received by the City on December 16, 2021. The City disbursed the CAPP funds on February 25, 2022 in the amount of approximately $4.7 million which was past the 60-day requirement. Additionally, we selected a sample of 60 customers totaling approximately $53,000 stratified between electric, water, and wastewater services and noted 3 of the samples where the City had credited the customer accounts in amounts that exceeded the eligible amounts billed during the period net of subsequent payments and adjustments from March 4, 2020 to June 15, 2021. Two of the three exceptions were residential water customers with a combined over award of $40.89 and one exception was for a commercial electric customer with an over award of $14.60. Cause and Effect: In discussing the 60-day disbursement condition with the City, management stated the focus was on disbursing the funds correctly. For the CAPP funds, the holidays impacted the disbursement timeline. For the CWWAPP funds, the first disbursement did not utilize all the funds. Therefore, management prepared a second disbursement to utilize the funds provided by the State which was 87 days outside the 60-day requirement. All three customer account over awards included partial cash payments and/or adjustments subsequent to management’s initial determination of delinquent account balances eligible for bill credits as defined by the grant guidance, but prior to the credit application date. The timing of the initial credit balance determinations versus the posting of ongoing adjustments could create differences in the allowable credit balances. The City’s manual review process of the adjustments did not identify the discrepancies. Questioned Costs: $55.49 Whether the sampling was a statistically valid sample: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend the City enhance their internal controls to include a timeline that would comply with the grant requirements. In the event, such timelines can not be adhered to, the City should work with the grantor for a time extension. For accounts with multiple adjustments, a more detailed review of the accounts should be performed if adjustments or cash payments are made subsequent to the City’s credit amount determination. Management’s Response: Management agrees with this finding. In order to ensure adherence to the stipulated 60-day window for credit applications, we have initiated immediate testing of bill notices upon receipt of CWWAPP disbursement checks. Simultaneously, a secondary query has been implemented to validate consistency between the initial query and the present data. To mitigate the risk of over awarding eligible customers, a final query will be conducted prior to disbursement to confirm the accuracy of the awarded amounts for each eligible account.
Finding 2022-002 – Allowable Costs/Costs Principles and Period of Performance Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN Number: 21.027 Federal Agency: United States Department of the Treasury Federal Award Year: 2022 Grant number: CAPP-PN-2022-05, CA 3010001, and 256399-01 Pass-Through Entity: State of California, Department of Community Services & Development and State Water Resources Control Board Criteria: The State of California (the State) passed through funding to the City of Anaheim (the City) for the California Arrearage Payment Program for electric customers (CAPP) and the California Water and Wastewater Arrearage Payment Program (CWWAPP). Both CAPP and CWWAPP have a provision that required the City to allocate payments to the customer accounts within 60 days of receiving payment from the State. Specifically, per section B, Program Requirements, of the California Water and Wastewater arrearage payment program guidelines, there is a requirement that notes “Water systems that participate in the program must allocate payments as bill credits to customer accounts within 60 days of receiving payment .” Per CAPP Program Notice No. 2022-01, there is a requirement that notes “Within 60 days of receiving CAPP funds, a utility applicant shall issue CAPP assistance benefits to customers as bill credits and include a statement that the credits are a result of California’s CAPP funding.” Additionally, both CAPP and CWWAPP provided for the funds to be utilized for customers arrearages accrued during the COVID-19 pandemic bill relief period of March 4, 2020 through June 15, 2021 net of any late fees which are to be waived. CWWAPP provisions are included in Section B Program Requirements and Appendix A, Section 1, Eligibility of the California Water and Wastewater arrearage payment program guidelines. For CAPP the eligibility determinations are included in the 2022 CAPP Frequently Asked Questions. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designated to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are allowable and adhere to the required period of performance. Condition and Context: The City made two disbursements under the CWAPP program for water customers on March 2, 2022 and June 21, 2022. The water funds were received by the City on January 25, 2022. The second disbursement made by the City on June 21, 2022 in the amount of approximately $102,000 was not within the 60-day requirement. The CAPP funds were received by the City on December 16, 2021. The City disbursed the CAPP funds on February 25, 2022 in the amount of approximately $4.7 million which was past the 60-day requirement. Additionally, we selected a sample of 60 customers totaling approximately $53,000 stratified between electric, water, and wastewater services and noted 3 of the samples where the City had credited the customer accounts in amounts that exceeded the eligible amounts billed during the period net of subsequent payments and adjustments from March 4, 2020 to June 15, 2021. Two of the three exceptions were residential water customers with a combined over award of $40.89 and one exception was for a commercial electric customer with an over award of $14.60. Cause and Effect: In discussing the 60-day disbursement condition with the City, management stated the focus was on disbursing the funds correctly. For the CAPP funds, the holidays impacted the disbursement timeline. For the CWWAPP funds, the first disbursement did not utilize all the funds. Therefore, management prepared a second disbursement to utilize the funds provided by the State which was 87 days outside the 60-day requirement. All three customer account over awards included partial cash payments and/or adjustments subsequent to management’s initial determination of delinquent account balances eligible for bill credits as defined by the grant guidance, but prior to the credit application date. The timing of the initial credit balance determinations versus the posting of ongoing adjustments could create differences in the allowable credit balances. The City’s manual review process of the adjustments did not identify the discrepancies. Questioned Costs: $55.49 Whether the sampling was a statistically valid sample: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend the City enhance their internal controls to include a timeline that would comply with the grant requirements. In the event, such timelines can not be adhered to, the City should work with the grantor for a time extension. For accounts with multiple adjustments, a more detailed review of the accounts should be performed if adjustments or cash payments are made subsequent to the City’s credit amount determination. Management’s Response: Management agrees with this finding. In order to ensure adherence to the stipulated 60-day window for credit applications, we have initiated immediate testing of bill notices upon receipt of CWWAPP disbursement checks. Simultaneously, a secondary query has been implemented to validate consistency between the initial query and the present data. To mitigate the risk of over awarding eligible customers, a final query will be conducted prior to disbursement to confirm the accuracy of the awarded amounts for each eligible account.
Finding 2022-002 – Allowable Costs/Costs Principles and Period of Performance Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN Number: 21.027 Federal Agency: United States Department of the Treasury Federal Award Year: 2022 Grant number: CAPP-PN-2022-05, CA 3010001, and 256399-01 Pass-Through Entity: State of California, Department of Community Services & Development and State Water Resources Control Board Criteria: The State of California (the State) passed through funding to the City of Anaheim (the City) for the California Arrearage Payment Program for electric customers (CAPP) and the California Water and Wastewater Arrearage Payment Program (CWWAPP). Both CAPP and CWWAPP have a provision that required the City to allocate payments to the customer accounts within 60 days of receiving payment from the State. Specifically, per section B, Program Requirements, of the California Water and Wastewater arrearage payment program guidelines, there is a requirement that notes “Water systems that participate in the program must allocate payments as bill credits to customer accounts within 60 days of receiving payment .” Per CAPP Program Notice No. 2022-01, there is a requirement that notes “Within 60 days of receiving CAPP funds, a utility applicant shall issue CAPP assistance benefits to customers as bill credits and include a statement that the credits are a result of California’s CAPP funding.” Additionally, both CAPP and CWWAPP provided for the funds to be utilized for customers arrearages accrued during the COVID-19 pandemic bill relief period of March 4, 2020 through June 15, 2021 net of any late fees which are to be waived. CWWAPP provisions are included in Section B Program Requirements and Appendix A, Section 1, Eligibility of the California Water and Wastewater arrearage payment program guidelines. For CAPP the eligibility determinations are included in the 2022 CAPP Frequently Asked Questions. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designated to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are allowable and adhere to the required period of performance. Condition and Context: The City made two disbursements under the CWAPP program for water customers on March 2, 2022 and June 21, 2022. The water funds were received by the City on January 25, 2022. The second disbursement made by the City on June 21, 2022 in the amount of approximately $102,000 was not within the 60-day requirement. The CAPP funds were received by the City on December 16, 2021. The City disbursed the CAPP funds on February 25, 2022 in the amount of approximately $4.7 million which was past the 60-day requirement. Additionally, we selected a sample of 60 customers totaling approximately $53,000 stratified between electric, water, and wastewater services and noted 3 of the samples where the City had credited the customer accounts in amounts that exceeded the eligible amounts billed during the period net of subsequent payments and adjustments from March 4, 2020 to June 15, 2021. Two of the three exceptions were residential water customers with a combined over award of $40.89 and one exception was for a commercial electric customer with an over award of $14.60. Cause and Effect: In discussing the 60-day disbursement condition with the City, management stated the focus was on disbursing the funds correctly. For the CAPP funds, the holidays impacted the disbursement timeline. For the CWWAPP funds, the first disbursement did not utilize all the funds. Therefore, management prepared a second disbursement to utilize the funds provided by the State which was 87 days outside the 60-day requirement. All three customer account over awards included partial cash payments and/or adjustments subsequent to management’s initial determination of delinquent account balances eligible for bill credits as defined by the grant guidance, but prior to the credit application date. The timing of the initial credit balance determinations versus the posting of ongoing adjustments could create differences in the allowable credit balances. The City’s manual review process of the adjustments did not identify the discrepancies. Questioned Costs: $55.49 Whether the sampling was a statistically valid sample: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendation: We recommend the City enhance their internal controls to include a timeline that would comply with the grant requirements. In the event, such timelines can not be adhered to, the City should work with the grantor for a time extension. For accounts with multiple adjustments, a more detailed review of the accounts should be performed if adjustments or cash payments are made subsequent to the City’s credit amount determination. Management’s Response: Management agrees with this finding. In order to ensure adherence to the stipulated 60-day window for credit applications, we have initiated immediate testing of bill notices upon receipt of CWWAPP disbursement checks. Simultaneously, a secondary query has been implemented to validate consistency between the initial query and the present data. To mitigate the risk of over awarding eligible customers, a final query will be conducted prior to disbursement to confirm the accuracy of the awarded amounts for each eligible account.
Finding 2022-007: Unallowable Costs / Cash Management Criteria: As stated in 2 CFR 200.303, the non-Federal entity (i.e. the Organization) 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: Astraea charged unallowed overhead costs to a Federal grant. These unallowable expenses were charged to the Federal government and cash was collected by Astraea. Cause: Astraea did not have a procedure in place to ensure all expenses charged to the Federal grants were allowable. Context: During the audit, we noted Astaea's internal control processes were not effective, evidenced by the recording and billing of unallowable overhead costs. Effect: Unallowable costs were billed to the Federal Government. Questioned Costs: None noted. These unallowable costs were moved to refundable advance. Identification as a Repeat Finding: No Recommendation: We recommend Astraea develop a more stringent internal control process surrounding the review and approval process for expenses recorded to Federal projects.