Federal Awarding Agency: USEDImpact: Significant Deficiency, NoncomplianceAL Number and Title: 84.007, 84.033, 84.063, 84.268, 84.379 Student Financial Assistance ClusterFederal Award Number: P063P210010Applicable Compliance Requirement: Special Tests and ProvisionsCondition and Context:The enrollment effective date reported to the National Student Loan Database System (NSLDS) for five of the ten sampled students from the UAS campus was incorrect and did not match the correct last dates of attendance on file in the institution?s records.Cause:At the UAS campus, there is a process that is run by the registrar for unofficial withdrawals at the end of every semester that overrides the correct institutional last date of attendance with the last date of the semester. This incorrect date is then reported to the Clearinghouse and ultimately NSLDS.Criteria:The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Additionally, 2 CFR 200.303 states that nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.Effect:UAS was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.Questioned Costs:NoneRecommendation:We recommend that UAS work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance prior to being reported to the Clearinghouse.Views of Responsible Officials:Management agrees with the finding.
Prior Year Finding: 2021-024Federal Awarding Agency: USEDImpact: Significant Deficiency, NoncomplianceAL Number and Title: 84.425D ESSER ? COVID-1984.425U ARP ESSER Fund ? COVID-19Federal Award Number: S425D210020, S425U210020Applicable Compliance Requirement: Subrecipient MonitoringCondition:DEED staff did not document risk assessments for non-Local Educational Agency (LEA) subrecipients.Context:Prior to the ESSER program, DEED rarely made subawards to entities that were not LEAs. Under the ESSER program DEED must subgrant 90 percent of funding to LEAs. The remaining 10 percent of funding can be allocated by DEED with greater discretion and includes subawards to non-LEAs. DEED staff did not conduct ESSER-specific risk assessments for LEAs. Instead, DEED staff relied on risk assessments performed for a different federal program, which was limited to LEAs.Cause:Risk assessments were not performed for non-LEA subrecipients because DEED utilized a risk assessment created for a different federal program, which only made grants to LEAs. According to DEED staff, formalized monitoring tools for non-LEA subrecipients will be implemented beginning in FY 23.Criteria:Title 2 CFR 200.303(a) requires the State to establish and maintain effective internal control over the federal award that provides reasonable assurance that the State is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the grant awards.Title 2 CFR 200.332(b) requires the State to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining appropriate subrecipient monitoring.Effect:Not performing risk assessments and not implementing formalized monitoring tools for all subrecipients could potentially result in inappropriate use of federal awards.Questioned Costs:NoneRecommendation:DEED?s DAS director should update risk assessment and monitoring procedures to include non-LEAs to ensure all ESSER subrecipients receive an appropriate level of monitoring.Views of Responsible Officials:Management agrees with the finding.
Prior Year Finding: 2021-023Federal Awarding Agency: U.S. Department of Education (USED)Impact: Material Weakness, Material NoncomplianceAL Number and Title: 84.425D Elementary and Secondary School Emergency Relief Fund (ESSER) ? COVID-1984.425U American Rescue Plan ? Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ? COVID-19Federal Award Number: S425D210020, S425U210020Applicable Compliance Requirement: ReportingCondition:FY 22 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for ESSER and ARP ESSER did not occur for 72 subawards.Context:FFATA requires information on federal awards be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees, such as the State of Alaska, use to capture and report subaward and executive compensation data regarding first-tier subawards. According to DEED procedures, on a monthly basis DEED staff prepares a submission to FSRS to identify initial subaward obligations greater than $30,000. This submission is reviewed and entered into FSRS. The FSRS printout is compared to the FSRS submission to verify the data was accurately captured.Auditors determined DEED staff did not retain documentation of the FSRS printout or verify the input was accurate. Auditors tested all subawards issued during FY 22 for the ESSER and ARP ESSER subprograms. Of the 75 subawards tested, 72 subawards were not reported, including 48 ARP ESSER subawards totaling $319,460,805 and 24 ESSER subawards totaling $8,854,035.[See Schedule of Findings and Questioned Costs for chart/table.]Cause:The ARP ESSER funding was established in the State?s accounting system as a capital appropriation. Subawards issued under the ARP ESSER appropriation were not reported to FSRS due to a flaw in DEED?s FFATA reporting tool, which was not designed to capture capital appropriations. According to DEED management, resolving prior and current year issues through the FFATA help desk has been difficult. As a result, DEED discontinued FFATA reporting after the April 2022 submission.Criteria:Title 2 CFR 200.303 requires the State to establish and maintain effective internal control over the federal award that provides reasonable assurance that the State is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the grant awards.Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made; include information about each obligating action in accordance with submission instructions; and include the names and total compensation of each of the subrecipient?s five most highly compensated executives if revenue thresholds are met and the executive compensation is not available to the public.Effect:Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding.Questioned Costs:NoneRecommendation:DEED?s Division of Administrative Services (DAS) director should ensure FFATA reporting procedures are followed and that the FFATA reporting tool is updated to ensure subaward reports are complete.Views of Responsible Officials:The department partially agrees with Finding 2022-026. The department agrees with the count of 72 separate awards not being reported, however the department disagrees with the specific dollar amount listed as ESSER II subawards were not reported. The amount listed is missing $5,483. This amount was awarded to a school district that also received ESSER II SEA Reserve funding under the same grant award and the FFATA reporting system has no mechanism to differentiate between mandatory funding and SEA Reserve funding. Per 2 CFR ? 170.220(b) and FFATA guidance documents, if an award increases to greater than the $30,000 reporting threshold, the full amount of the award must be reported, not just the portion that exceeded the threshold.Auditor?s Concluding Remarks:Management?s response did not persuade the auditor to revise the finding. DEED management stated the finding amount is missing $5,483. A subaward to the school district totaling $61,165 was included in the finding. Subsequently, an additional subaward was made totaling $5,483, which was not included in the finding because it did not meet the threshold for reporting under Title 2 Code of Federal Regulations Part 170 Appendix A.
Federal Awarding Agency: U.S. Department of Education (USED)Impact: Significant Deficiency, NoncomplianceAL Number and Title: 84.425F HEERF Minority Serving Institution (MSI) PortionFederal Award Number: P425L200248Applicable Compliance Requirement: Allowable Costs/Cost PrinciplesCondition and Context:During the testing of the University of Alaska Fairbanks (UAF) MSI expenditures there was an observed instance, among the forty that were tested, of an interdepartmental transaction being claimed as a reimbursable expenditure. Students from the MacClean House dorm, which is operated by the UAF Residence Life unit, were required to quarantine in the MacLean House dorm, which is operated by the College of Rural and Community Development (CRCD) unit. This resulted in the UAF Residence Life unit paying the CRCD unit for the students' housing costs. This transaction was included as a reimbursable expenditure, despite having a net $0 impact on the income statement.Cause:UAF had not considered the possibility that interdepartmental transactions could be disallowed. Due to a lack of authoritative guidance at the time, the campus relied on the Frequently Asked Questions (FAQ) to determine allowability which made no mention of lost revenue related to interdepartmental transactions.Criteria:Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In addition, Per Uniform Guidance 200.34 expenditures on the accrual basis may be: cash disbursements for direct charges for property and services, the value of third-party in-kind contributions applied, and the net increase or decrease in the amounts owed by non-federal entity.Effect:The University claimed costs that were not allowable.Questioned Costs:$2,100.97 - ALN 84.425F - Grant Award P425L200248Recommendation:We recommend the University of Alaska Fairbanks should not claim interdepartmental expenditures as institutional expenditures.Views of Responsible Officials:Management agrees with the finding.
Prior Year Finding: 2021-024Federal Awarding Agency: USEDImpact: Significant Deficiency, NoncomplianceAL Number and Title: 84.425D ESSER ? COVID-1984.425U ARP ESSER Fund ? COVID-19Federal Award Number: S425D210020, S425U210020Applicable Compliance Requirement: Subrecipient MonitoringCondition:DEED staff did not document risk assessments for non-Local Educational Agency (LEA) subrecipients.Context:Prior to the ESSER program, DEED rarely made subawards to entities that were not LEAs. Under the ESSER program DEED must subgrant 90 percent of funding to LEAs. The remaining 10 percent of funding can be allocated by DEED with greater discretion and includes subawards to non-LEAs. DEED staff did not conduct ESSER-specific risk assessments for LEAs. Instead, DEED staff relied on risk assessments performed for a different federal program, which was limited to LEAs.Cause:Risk assessments were not performed for non-LEA subrecipients because DEED utilized a risk assessment created for a different federal program, which only made grants to LEAs. According to DEED staff, formalized monitoring tools for non-LEA subrecipients will be implemented beginning in FY 23.Criteria:Title 2 CFR 200.303(a) requires the State to establish and maintain effective internal control over the federal award that provides reasonable assurance that the State is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the grant awards.Title 2 CFR 200.332(b) requires the State to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining appropriate subrecipient monitoring.Effect:Not performing risk assessments and not implementing formalized monitoring tools for all subrecipients could potentially result in inappropriate use of federal awards.Questioned Costs:NoneRecommendation:DEED?s DAS director should update risk assessment and monitoring procedures to include non-LEAs to ensure all ESSER subrecipients receive an appropriate level of monitoring.Views of Responsible Officials:Management agrees with the finding.
Prior Year Finding: 2021-023Federal Awarding Agency: U.S. Department of Education (USED)Impact: Material Weakness, Material NoncomplianceAL Number and Title: 84.425D Elementary and Secondary School Emergency Relief Fund (ESSER) ? COVID-1984.425U American Rescue Plan ? Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ? COVID-19Federal Award Number: S425D210020, S425U210020Applicable Compliance Requirement: ReportingCondition:FY 22 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for ESSER and ARP ESSER did not occur for 72 subawards.Context:FFATA requires information on federal awards be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees, such as the State of Alaska, use to capture and report subaward and executive compensation data regarding first-tier subawards. According to DEED procedures, on a monthly basis DEED staff prepares a submission to FSRS to identify initial subaward obligations greater than $30,000. This submission is reviewed and entered into FSRS. The FSRS printout is compared to the FSRS submission to verify the data was accurately captured.Auditors determined DEED staff did not retain documentation of the FSRS printout or verify the input was accurate. Auditors tested all subawards issued during FY 22 for the ESSER and ARP ESSER subprograms. Of the 75 subawards tested, 72 subawards were not reported, including 48 ARP ESSER subawards totaling $319,460,805 and 24 ESSER subawards totaling $8,854,035.[See Schedule of Findings and Questioned Costs for chart/table.]Cause:The ARP ESSER funding was established in the State?s accounting system as a capital appropriation. Subawards issued under the ARP ESSER appropriation were not reported to FSRS due to a flaw in DEED?s FFATA reporting tool, which was not designed to capture capital appropriations. According to DEED management, resolving prior and current year issues through the FFATA help desk has been difficult. As a result, DEED discontinued FFATA reporting after the April 2022 submission.Criteria:Title 2 CFR 200.303 requires the State to establish and maintain effective internal control over the federal award that provides reasonable assurance that the State is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the grant awards.Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made; include information about each obligating action in accordance with submission instructions; and include the names and total compensation of each of the subrecipient?s five most highly compensated executives if revenue thresholds are met and the executive compensation is not available to the public.Effect:Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding.Questioned Costs:NoneRecommendation:DEED?s Division of Administrative Services (DAS) director should ensure FFATA reporting procedures are followed and that the FFATA reporting tool is updated to ensure subaward reports are complete.Views of Responsible Officials:The department partially agrees with Finding 2022-026. The department agrees with the count of 72 separate awards not being reported, however the department disagrees with the specific dollar amount listed as ESSER II subawards were not reported. The amount listed is missing $5,483. This amount was awarded to a school district that also received ESSER II SEA Reserve funding under the same grant award and the FFATA reporting system has no mechanism to differentiate between mandatory funding and SEA Reserve funding. Per 2 CFR ? 170.220(b) and FFATA guidance documents, if an award increases to greater than the $30,000 reporting threshold, the full amount of the award must be reported, not just the portion that exceeded the threshold.Auditor?s Concluding Remarks:Management?s response did not persuade the auditor to revise the finding. DEED management stated the finding amount is missing $5,483. A subaward to the school district totaling $61,165 was included in the finding. Subsequently, an additional subaward was made totaling $5,483, which was not included in the finding because it did not meet the threshold for reporting under Title 2 Code of Federal Regulations Part 170 Appendix A.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
2022 ? 001Federal Agency: Department of EducationFederal Program Name: Education Stabilization Fund - Higher Education Emergency Relief FundAssistance Listing Numbers: 84.425E and 84.425FFederal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2019-20, 2020-21, and 2021-22 award yearsAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and Other MattersCriteria or Specific Requirement:The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report.Condition:California, Cheyney, Clarion, Edinboro, Lock Haven and Mansfield Universities were not in compliance with some or all of the reporting requirements for the HEERF program or have appropriate review documentation for reporting. Millersville and Bloomsburg Universities also did not have appropriate review documentation for reporting.Questioned Costs:N/AContext:During our testing of HEERF reporting requirements on the State System, we noted:1) Noncompliant Student Reporting:? California University (P425E200998): Two of the two student reports selected for testing were missing support for timely posting.? Cheyney University (P425E202680): Two of the two student reports selected for testing were not displayed on their website.? Clarion University (P425E201213): One of the two student reports selected for testing was not displayed on their website. The only student report posted to the website was missing key item (1) and one of the other key reporting items did not tie to supporting documentation.? Edinboro University (P425E202644): One of the two student reports selected for testing were not displayed on their website. The only student report posted to the website included key items that did not tie to supporting documentation. In addition, there was not supporting documentation maintain to support timely posting.? Lock Haven University (P425E204101): Two of the two student reports selected for testing did not include key items. One of the two reports were posted more than 10 days after the end of the quarter.? Mansfield University (P425E200712): Two of the two student reports selected for testing did not include key reporting items.2) Noncompliant Institutional Reporting:? California University (P425F202213): Two of two of the institutional reports selected for testing did not agree to supporting documentation. Two of the Two report additional did not maintain supporting documentation for posting.? Cheyney University (P425F201194): Two of the two Institutional reports selected for testing were posted more than 10 days after the end of the quarter.? Clarion University (P425F202040): One of the two institutional reports selected was not displayed on their website. The only institutional report posted to the website did not tie to supporting documentation.? Edinboro University (P425F201940): Two of the two institutional reports selected for testing were not posted timely.3) Lack of Documentation of Review:? Bloomsburg University (P425E200414) ? Student? California University (P425E200998 and P425F202213) ? Student, Institutional, and Annual? Cheyney University (P425E202680) ? Student? Clarion University (P425E201213 and P425F202040) ? Student and Institutional? Edinboro University (P425E202644) ? Student? Lock Haven University (P425E204101) ? Student? Mansfield University (P425E200712 and P425F200622) ? Student and Annual? Millersville University (P425F200614) ? InstitutionalCause:The policies and procedures of the universities did not ensure that grant reporting requirements were timely and accurately met.Effect:The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received.Repeat Finding:Yes ? Finding 2021-001Recommendation:The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately.Views of Responsible Officials:Management agrees with the finding and has developed a plan to correct the finding.
FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.
FINDING 2022-209An annual physical inventory was not completed for all storage facilities used by subdistributing agencies for the Emergency Food Assistance Program as required by federal guidance.Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Emergency Food Assistance ProgramAssistance Listing Number: 10.568Federal Award Number: 227IDID8P1103; 227IDID8Y8105; 227IDID2Q2204; 227IDID5Y8613Program Year: October 1, 2021 ? September 30, 2022; October 1, 2019 ? September 30, 2022; October 1, 2021 ? September 30, 2022; November 3, 2021 ? November 2, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Uniform Guidance included in 7 CFR 250.12(b) requires that State distributing agencies must conduct annual physical inventory of all storage facilities used by the distributing agency or the subdistirbuting agency. Such inventory must be reconciled annually with the storage facility?s inventory records and maintained on file by the agency which contracted with or maintained the storage facility.Condition: The Department staff only performed an annual physical inventory of 25 percent of the subdistributing agencies contracted with for the Emergency Food Assistance Program. Federal guidance requires that all State distributing agencies shall have an annual physical inventory and the Department currently partners with 5 subdistributing agencies. The inventory procedures have only been performed on 1 or 2 subdistributing agencies per fiscal year.Cause: The Department incorrectly interpreted the coverage requirements provided for State monitoring systems as also applicable for the physical inventory requirements related to subdistributing agencies. Those requirements are included in 7 CFR 251.10(e) and states that each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements. State agencies may not delegate this responsibility, and these reviews must cover at least 25 percent of all eligible recipient agencies. These reviews are separate from the guidance contained in 7 CFR 250.12(b) requiring annual physical inventory of all storage facilities.Effect: The Department did not properly design and implement internal controls to ensure compliance with the inventory requirements included in 7 CFR 250.12(b). The storage facilities not included in the annual physical inventory received commodity donations valued at $5,268,861 during the period of our audit.Recommendation: We recommend that the Department design and implement controls and procedures to ensure compliance with federal requirements covering the Emergency Food Assistance Program.Management?s View: The Department agrees with this finding.Corrective Action: With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement. If required by FNS and the compliance supplement, we will revise our control process in this program by July 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s effort to reach out to the grantor and gain further guidance on the definition of the entities that were considered subdistributing agencies during the audit. Recognizing that an entity can be a subdistributing agency and a recipient agency, we continue to assert that inventory monitoring and compliance with the requirements in 7 CFR 250.12(b) to ensure accountability for goods at storage facilities is required by the program and was not completed at all facilities. We will re-evaluate that determination of compliance if the grantor provides definitive guidance that this is not their intent with the requirements.
FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-210The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Type of Finding: Significant Deficiency, NoncomplianceAssistance Listing Title: Coronavirus State and Local Fiscal Recovery FundsAssistance Listing Number: 21.027Federal Award Number: 20-1982-0-1-806Program Year: March 3, 2021 ? December 31, 2024Federal Agency: Department of TreasuryCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities? responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.In addition, 2 CFR 25.300 states that (a) a recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier and (b) a recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier, as described in paragraph (a) of this section.Condition: The Department used Coronavirus State and Local Fiscal Recovery funds to provide financial support to hospitals during the COVID-19 pandemic. The Department was responsible for distributing these funds and created a process for hospitals to apply and receive funding. During testing, we identified 2 applications out of 8 reviewed, or 25 percent, that did not have unique entity identifier numbers attached to the documentation provided for testing, as required by 2 CFR 25.300.Cause: The Department had review procedures in place, but the reviews of subrecipient application documentation failed to detect the absence of unique entity identifier numbers. This number is required as part of the subgranting process.Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding.Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure adequate subrecipient applications are completed accurately and in compliance with federal requirements.Management?s View: The Department agrees with this finding.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.
FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.
FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.
FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.
FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.
FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.
FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.
FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.
FINDING 2022-201The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.The grant award from the U.S. Department of Health and Human Services (HHS) issued under Older Americans Act of 1965 requires recipients to submit the Federal Financial SF-425 Reports on a semi-annual basis. Federal Financial SF-425 Reports are due within 30 days for the periods ending March 31 and September 30 (due April 30 and October 30), and a final report is due within 90 days after September 30 (due December 30). If a final report is submitted by December 30, a semi-annual report is not required to be filed by October 30.Condition: The Federal Financial SF-425 Reports for the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, and 93.053) were not completed during State fiscal year 2022.The Federal Financial SF-425 Report should have been submitted for the periods ending September 30, 2021, and March 31, 2022, during our audit period. Prior Commission staff requested a filing extension from HHS for the September 2021 report. The HHS federal liaison approved the extension and requested specific dates of when to expect the report; however, the Commission was unable to provide additional details about the September extension or documentation of additional extensions for the March 2022 report.Cause: Commission staff did not complete the Federal Financial SF-425 Report during State fiscal year 2022 and did not receive or maintain appropriate documentation of extensions for past due reports. Commission staff stated that they believed the September 2021 e-mail approval covered all delinquent reports.Effect: The Federal Financial SF-425 Report is used to report the financial status of grant funds and expenditures of those funds and is generally supported by the underlying accounting records. Inaccurate or incomplete reporting could result in inaccurate information provided to users of the reports, including the federal funding agency, and could cause a disruption in federal funding due to noncompliance. The inability to complete and submit financial reports for an entire year also increases the risk of properly reconciling the data reported to the underlying records and ensuring that payments are only for allowable activities.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure compliance with federal reporting requirements and accurate and timely completion and submission of the Federal Financial SF-425 Report.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant.A reporting workbook has been created to track awards and reporting dates.Reporting period end dates and due dates will be added to fiscal staff calendars.A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.We will continue to keep our federal partners appraised of our progress through completion.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. We will review reporting procedures implemented as part of follow-up procedures completed in conjunction with the fiscal year 2023 Single Audit Report. We would like to emphasize that along with implementing a process for completing the past due and current reports, the Office should also include internal control activities that help ensure the processes are properly executed.
FINDING 2022-202The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Grants for Supportive Services and Senior Centers; Special Programs for the Aging; Title III, Part C, Nutrition Services; Nutrition Services Incentive ProgramAssistance Listing Number: 93.044; 93.045; 93.053Federal Award Number: 2001IDOASS; 2101IDOASS; 2201IDOASS; 2101IDOAHD; 2101IDOACM; 2201IDOAHD; 2101IDOANS; 2201IDOANSProgram Year: October 1, 2019 ? September 30, 2021; October 1, 2020 ? September 30, 2023; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2020 ? September 30, 2022; October 1, 2021 ? September 30, 2023Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.The Committee of Sponsoring Organizations of the Treadway Commission (COSO) published the Internal Control Integrated Framework, which provides a basis for organizations to design internal control procedures to ensure reliable financial reporting, effective and efficient operations, and compliance with applicable laws and regulations. Components of this framework include control activities and information and communication.Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System.Condition: The FFATA was developed to provide better transparency over management of federal grants and contracts. Reporting is required on allocations of federal funding of $30,000 or more through the FFATA website. The Commission is the primary recipient of the Aging Cluster Grant program (Assistance Listing Numbers 93.044, 93.045, 93.053). The Commission issued six subawards in excess of $30,000 to the six Area Agencies on Aging that required reporting under the FFATA guidelines.When discussing FFATA reporting requirements with the Commission, current staff were not aware of the requirement to complete the FFATA reports. No FFATA reports were submitted during our audit period, and as far as the Commission staff were aware, no FFATA reports had ever been submitted for the Commission.Cause: Commission staff were not aware of the FFATA reporting requirements and did not implement internal controls to ensure the accurate and timely submission of the FFATA reports.Effect: The FFATA reports are required to be submitted to the FFATA Subaward Reporting System, which makes the information available to the public in a searchable database. Late reporting, or non-reporting, impacts the integrity of that information. Additionally, without effective internal controls in place, there is an increased risk that an error or misreporting could occur and remain undetected and uncorrected.Recommendation: We recommend that the Commission design and implement well-documented internal control procedures to ensure the compliance with federal reporting requirements and accurate and timely completion and submission of FFATA reports.Management?s View: The Idaho Commission on Aging is in general agreement with the findings as stated by Legislative Services Office Single Audit Report for fiscal year 2022.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023.The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Auditor?s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit. These reports were completed after receiving the audit findings and we have not had an opportunity to review them. Additionally, the Office has not addressed the recommendation to improve internal controls over the reporting process for FFATA reporting and we continue to assert that improving the internal control activities around this process is critical to ensuring compliance with federal reporting requirements.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-208State Opioid Response program performance progress reports did not have documentation to support completion of a review for accuracy and compliance prior to submission.Type of Finding: Material WeaknessAssistance Listing Title: Opioid STRAssistance Listing Number: 93.788Federal Award Number: H79TI083282; H79TI081727Program Year: September 30, 2020 ? September 29, 2023; September 30, 2018 ? September 29, 2021Federal Agency: Health and Human ServicesCompliance Requirement: ReportingQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.Condition: During fiscal year 2022, the State Opioid Response program was required to submit 5 program performance reports to the grantor. A Department program specialist or project manager compiles the State Opioid Response program performance progress reports and a contract manager review and approves the reports. The approval of the performance progress reports for all five (5) reports tested under the State Opioid Response program was not documented. Department staff indicated that the approval process was verbal or through e-mails that were not retained, and we were unable to verify this process.Cause: The Department did not consider that documentation to support the review and approval of these performance progress reports was necessary to ensuring accuracy and compliance with reporting requirements.Effect: We did not identify errors in the performance progress reports we reviewed. However, without documentation of appropriate internal controls, there is an increased risk of errors occurring and going undetected, or errors being present in reports we did not review. Further, the Department could submit the performance progress reports with incomplete or inaccurate information required by the grant agreement.Recommendation: We recommend that the Department design and implement procedures to ensure sufficient documentation is maintained that supports the review and approval of the performance progress reports.Management?s View: The Department agrees with the finding.Corrective Action: Beginning April 1, 2023, all required federal reports will include the following statement, which will be signed and dated electronically by the approving reviewer before the report is submitted:? I, _______________________, have reviewed and approved this report prior to submission.Name, titleA copy of the approved and signed report will be retained in DBH?s electronic grant funding records.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We appreciate the Department?s view that the contract manager did complete reviews to ensure accuracy, but without documentation available to the auditors at the time we are completing auditing procedures it is difficult to verify if errors were detected, if they were properly corrected, and if the final version was then reviewed again to ensure accuracy. A clear documentation trail is critical to support accurate reporting and can also provide insight into improving the process so that errors do not continue to occur.
FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-212The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Related to Prior Finding: 2021-210Type of Finding: Material Weakness, Material NoncomplianceAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramAssistance Listing Number: 10.551; 10.561Federal Award Number: 22ID35051692301; 227IDID4S2514; 227IDID5Q3903; 227IDID6F1003; 227IDID4S2519; 227IDID4S2520; 227IDID4Q7503Program Year: October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2023; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022; October 1, 2021 ? September 30, 2022Federal Agency: Department of AgricultureCompliance Requirement: Special Tests and ProvisionsQuestioned Costs: NoneCriteria: The Department is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft, embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR section 274.8(b)(3)).Further, 7 CFR 274.5(c) states that an EBT Card is considered an accountable document. The State agency is required, at minimum, to provide the following security and control procedures relating to these documents:? Secure storage,? Access limited to authorized personnel,? Bulk inventory control records,? Subsequent control records maintained through the point of issuance or use, and? Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining control records.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out throughout the operation. Verifications, approvals, and authorizations are all control activities that support this objective.Condition: The Department utilizes 19 field offices spread over 7 regions for distribution of EBT cards. Each office is required monthly to complete logbooks that include the Idaho Issuance Log for Blank EBT Cards, Destruction Log for EBT Cards, Card Usage Report, and the Month End EBT Card Count. The monthly records are reviewed by an EBT specialist to determine inventory accuracy and that cards are being tracked correctly.As part of implementing the corrective action plan for Finding 2021-210 from the State of Idaho Single Audit for fiscal year 2021, the Department?s EBT supervisor began reviewing the EBT specialist?s reviews of monthly records on a quarterly basis. However, the EBT supervisor?s quarterly reviews for fiscal year 2022 did not begin until September 2022, which is in fiscal year 2023.During our review, we identified 7 instances out of a sample of 25 months, or 28 percent, in which we could not verify that the EBT specialist?s review of monthly records was either documented or completed at a sufficient level to identify errors or omissions.Cause: The reviews of some office logs and reports by an EBT specialist were not documented or completed. Additionally, the supervisory oversight of the EBT specialist was not completed at a level sufficient to identify the lack of documentation or ensure completion of the required reviews. The Department began implementing a corrective action plan to address the Finding 2021-210 issued in April 2022, but changes in control procedures were not implemented during our audit period.Effect: The lack of proper card security and inventory monitoring increases the risk of improper EBT card distribution and management. Without effective internal controls in operation, there is also an increased potential for further noncompliance with federal requirements.Recommendation: We recommend that the Department continue to improve oversight regarding the regional offices and supplement internal controls and documentation to ensure compliance with the EBT security requirements.Management?s View: The Department agrees with the finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staff reviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
FINDING 2022-211The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Related to Prior Finding: 2021-206Type of Finding: Significant Deficiency, Noncompliance, SEFA MisstatementAssistance Listing Title: Supplemental Nutrition Assistance Program (SNAP); WIC Special Supplemental Nutrition Program for Women, Infants, and Children; State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Special Education - Grants for Infants and Families; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises; Community-Based Child Abuse Prevention Grants; Block Grants for Community Mental Health Services; Sexually Transmitted Diseases (STD) Prevention and Control GrantsAssistance Listing Number: 10.551; 10.557; 10.561; 84.181; 93.391; 93.497; 93.590; 93.958; 93.977Federal Award Number: 22ID35051692301; 217IDID7W7003; 227IDID7F1003; H181X21016; NH75OT000105; 2202IDFSC6; 2101IDBCC6; B09SM083970; NH25PS005171Program Year: October 1, 2021 ? September 30, 2022; October 1, 2020 ? September 30, 2021; October 1, 2021 ? September 30, 2021; July 1, 2021 ? September 30, 2022; June 1, 2021 ? May 31, 2023; October 1, 2020 ? September 30, 2025; October 1, 2020 ? September 30, 2025; March 15, 2021 ? March 14, 2023; January 1, 2019 ? December 31, 2023Federal Agency: Department of Agriculture; Department of Education; Health and Human ServicesCompliance Requirement: Code of Federal Regulations (CFR) 2 CFR 200.510(b)Questioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR 200.510(b) requires the State to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the fiscal year that must include the total federal awards expended. State agencies are required to report federal expenditures incurred for each federal program during the State fiscal year to the Office of the State Controller (Office) through the SEFA closing package. The Office provides instructions on the completion of the closing package.The Uniform Guidance included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award.The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include things like approvals, authorizations, verifications, reconciliations, and segregation of duties.The Office of Management and Budget (OMB) Memorandum 20-26, Appendix A, states that in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, recipients and subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the SEFA and audit report findings.Condition: The Department did not separately identify COVID-19 Emergency Acts related expenditures, as required by OMB Memorandum 20-26, on their SEFA submission for multiple programs. The specific programs include the following:? Supplemental Nutrition Assistance Program (Assistance Listing Number (AL) 10.551) for the amount of $38,370,588? Special Supplemental Nutrition Program for Women, Infants, and Children (AL 10.557) for the amount of $1,547,158? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (AL 10.561) for the amount of $354,983? Special Education-Grants for Infants and Families (AL 84.181) for the amount of $265,777? Activities to Support State, Tribal, Local and Territorial Health Department Response to Public Health or Healthcare Crises (AL 93.391) for the amount of $3,387,573? Family Violence Prevention and Services/Sexual Assault/Rape Crisis Services and Supports (AL 93.497) for the amount of $183,807? Community-Based Child Abuse Prevention Grants (AL 93.590) for the amount of $156,539? Block Grants For Community Mental Health Services (AL 93.958) for the amount of $389,232? Preventive Health Services-Sexually Transmitted Diseases Control Grants (AL 93.977) for the amount of $156,712The total amount of expenditures for each of the above listed programs were accurately reported; however, specific identification of COVID-19 Emergency Acts expenditures was not accurately identified.Cause: The Department has a review process in place for closing packages that is intended to detect and correct errors. However, the review of the fiscal year 2022 SEFA closing package was not completed at a level of detail sufficient to properly identify COVID-19 Emergency Acts expenditures.Effect: The Department did not separately identify the COVID-19 Emergency Acts expenditures on their SEFA in order to maximize transparency and accountability. In total, $44,812,369 across 9 programs was not properly identified as COVID-19 Emergency Acts related expenditures, as required.After we identified this issue, the amounts were separated, and the COVID-19 identification was added to the programs in a subsequent submission of SEFA information.Recommendation: We recommend that the Department improve the review process for the SEFA closing package to include training and specific procedures at a level of detail sufficient to identify inaccuracies or omission of required information such as the COVID-19 Emergency Acts expenditures.Management?s View: The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.Corrective Action: This corrective action plan is complete. Effective immediately, we will monitor awards for any new COVID-19 funding, but we don?t believe that there will be any new COVID-19 awards. All existing awards have been confirmed as being reported as COVID-19 funding.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit. We would like to emphasize that internal controls should be designed to meet stated objectives. In this case, the objective is to provide requested information to the Office of the State Controller on closing packages that contain specific instructions, so that the Office can prepare the statewide Schedule of Expenditures of Federal Assistance (SEFA). The fact that the internal controls designed and implemented by the Department are only intended to identify material errors in the SEFA closing package significantly increases the risk that individually smaller errors will go undetected and uncorrected and potentially could result in an aggregated material misstatement. Additionally, minimalizing accuracy within reporting elements, such as the COVID-19 designation, increases the risk that these errors would go entirely undetected, even if they were material. We would also like to emphasize that including standard procedures to be alert for changing and new requirements is an important part of a strong internal control environment. While the COVID-19 funds may be in the process of being spent down, new very large programs are in process and could also have unique requirements that should be assessed.
Finding 2022-009 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866St. Joseph?s Hospital and Medical Center ? All Research and Development Cluster awards listed in Finding 2022-008 above.Criteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?Condition At St. Joseph?s Hospital and Medical center, internal controls over allowability criteria with regard to indirect expenditures were not performed throughout the entire period.Cause Management did not have a process in place for the entire fiscal year to evaluate if indirect costs charged to the grant exceeded the amount allowed under the grant agreement.Effect or potential effect Unallowable and inaccurate indirect expenditures could be charged to the federal program.Questioned costs None.Context We issued a significant deficiency related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a significant deficiency consistent with the prior year finding.Starting in January 2022, management began reconciling the costs for all grants and made adjusting entries to correct the amount of indirect costs previously charged to the award that were in excess of amounts allowed.The total indirect expenses make up $2.7 million or 22% of the $12.6 million research and development expenditures for St. Joseph?s Hospital and Medical Center, which represent 16% of the total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-010.Recommendation We recommend management implement and retain evidence of internal controls over indirect expenses charged to the grant to ensure that the rates used are in accordance with the federally negotiated rate or grant agreement and the total expenditures do not exceed the allowable limit.Views of responsibleofficials Management agrees with the finding and implemented corrective action in January 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-010 ? Allowable Costs/Cost Principles (Salary Cap)Identification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866St. Joseph?s Hospital and Medical Center ? All Research and Development Cluster awards listed in Finding 2022-008 above.Criteria or specific requirement (including statutory, regulatory, orother citation) 2 CFR 200.303(a) requires that 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).?Condition St. Joseph?s Hospital and Medical Center did not retain evidence of review of the NIH salary cap requirement.Cause Management did not retain evidence of review and approval of NIH salary cap limited employees to support allowable costs/cost principles.Effect or potential effect Unallowable and inaccurate payroll expenditures surpassing the NIH salary cap could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-011.Recommendation St. Joseph?s Hospital and Medical Center should retain evidence of its review to ensure the NIH salary cap is not exceeded.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-011 ? Special Tests and Provisions ? Key PersonnelIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.279, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.830, 93.838, 93.847, 93.853, 93.856, 93.865, 93.866, 93.880, and 98.837St. Joseph?s Hospital and Medical Center ? All Research and Development Cluster awards listed in Finding 2022-008 above.Criteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that 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).?Condition St. Joseph?s Hospital and Medical Center?s internal controls over key personnel were not designed and operating effectively since level of effort certifications were not completed and signed timely by key personnel on grants.Cause St. Joseph?s Hospital and Medical Center did not complete certifications and sign level of effort certifications during the year or shortly thereafter.Effect or potential effect Prior approvals for change in key personnel specified in the application or the federal award; and the disengagement of key personnel from the project for more than three months, or a 25% reduction in time devoted to the project by the approved project director or principal investigator may not be adequately reported to the federal awarding agencies.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Although, St. Joseph?s Hospital and Medical Center did have completed and signed level-of-effort certifications for 17 key personnel selected for compliance testing, we noted the certifications were not prepared and signed during the year ended June 30, 2022 or prior to 6 months after year-end.St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-012.Recommendation St. Joseph?s Hospital and Medical Center should design internal controls over key personnel to ensure that certifications of level of effort by key personnel are completed and signed in a timely manner. Monitoring of the level of effort spent by key personnel should be performed throughout the year to ensure that the minimum requirements are being met.Views of responsible officials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-016 ? Subrecipient MonitoringIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.279, 93.853, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?Condition St. Joseph?s Hospital and Medical Center?s subrecipient monitoring tracking document, while designed appropriately, is not being maintained effectively and includes errors, since line items on the tracking document for several subrecipients appear to be incorrect with regards to audit findings. Findings appear to have been left off of the tracking document or added incorrectly for a particular subrecipient or may not apply to the subrecipient but to a different subrecipient.Cause St. Joseph?s Hospital and Medical Center did not have internal controls and policies and procedures in place to effectively maintain its subrecipient monitoring tracking document.Effect or potential effect If the subrecipient monitoring tracking document includes errors, St. Joseph?s Hospital and Medical Center may not appropriately modify its ongoing monitoring and risk assessment procedures based on any findings noted in a subrecipients report.Questioned costs None.Context St. Joseph?s Hospital and Medical Center?s subrecipient expenditures totaled $4.7 million during the period, which represented 37% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million and 6% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is not a repeat finding.Recommendation We recommend St. Joseph?s Hospital and Medical Center implement controls over the maintenance of the subrecipient monitoring tracking document to ensure the tracking document is accurately representing the findings for each subrecipient so that the subrecipients may be effectively monitored.Views of responsibleofficials Management agrees with the finding and will implement corrective action by June 2023.
Finding 2022-018 ? Procurement and Suspension and DebarmentIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, and 93.853See Schedule of Findings and Questioned Costs for chart/tableSt. Joseph?s Hospital and Medical CenterCriteria or specific requirement (including statutory, regulatory, orother citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR 200.318 (i) General Procurement Standards states, ?the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.?Criteria or specific requirement (including statutory, regulatory, orother citation) (continued) 2 CFR 200.320 (c) Noncompetitive procurement states, ?there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply:(1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);(2) The item is available only from a single source;(3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;(4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or(5) After solicitation of a number of sources, competition is determined inadequate.?Condition St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Cause St. Joseph?s Hospital and Medical Center did not have effective internal controls over preparation and retention of the rationale of the method of procurement.Effect or potential effect Noncompliance with the procurement documentation requirements of 2 CFR 200.318 (i) and without adequate documentation of sole source justification there is greater potential for noncompliance with noncompetitive procurement requirements in 2 CFR 200.320 (c).Questioned costs None.Context For 3 of 5 procurements selected for testing, St. Joseph?s Hospital and Medical Center indicated the procurement was a noncompetitive procurement (sole source) but did not have documentation to support the rationale for the sole source procurement.We selected and tested five procurements with expenditures totaling $151,515 from a population of 6 procurements with expenditures totaling $161,960 charged to the St. Joseph?s Hospital and Medical Center during the year ended June 30, 2022. The three noncompetitive procurements tested totaled $43,356.Identification as a repeat finding, if applicable This is not a repeat finding.Recommendation St. Joseph?s Hospital and Medical Center should retain written documentation for procurements documenting the history of the procurement prior to the procurement of goods or services, including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.Views of responsibleofficials Management agrees with the finding and will implement corrective action by April 2023.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-009 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866St. Joseph?s Hospital and Medical Center ? All Research and Development Cluster awards listed in Finding 2022-008 above.Criteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?Condition At St. Joseph?s Hospital and Medical center, internal controls over allowability criteria with regard to indirect expenditures were not performed throughout the entire period.Cause Management did not have a process in place for the entire fiscal year to evaluate if indirect costs charged to the grant exceeded the amount allowed under the grant agreement.Effect or potential effect Unallowable and inaccurate indirect expenditures could be charged to the federal program.Questioned costs None.Context We issued a significant deficiency related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a significant deficiency consistent with the prior year finding.Starting in January 2022, management began reconciling the costs for all grants and made adjusting entries to correct the amount of indirect costs previously charged to the award that were in excess of amounts allowed.The total indirect expenses make up $2.7 million or 22% of the $12.6 million research and development expenditures for St. Joseph?s Hospital and Medical Center, which represent 16% of the total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-010.Recommendation We recommend management implement and retain evidence of internal controls over indirect expenses charged to the grant to ensure that the rates used are in accordance with the federally negotiated rate or grant agreement and the total expenditures do not exceed the allowable limit.Views of responsibleofficials Management agrees with the finding and implemented corrective action in January 2022.
Finding 2022-010 ? Allowable Costs/Cost Principles (Salary Cap)Identification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866St. Joseph?s Hospital and Medical Center ? All Research and Development Cluster awards listed in Finding 2022-008 above.Criteria or specific requirement (including statutory, regulatory, orother citation) 2 CFR 200.303(a) requires that 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).?Condition St. Joseph?s Hospital and Medical Center did not retain evidence of review of the NIH salary cap requirement.Cause Management did not retain evidence of review and approval of NIH salary cap limited employees to support allowable costs/cost principles.Effect or potential effect Unallowable and inaccurate payroll expenditures surpassing the NIH salary cap could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-011.Recommendation St. Joseph?s Hospital and Medical Center should retain evidence of its review to ensure the NIH salary cap is not exceeded.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.