Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Reference Number: 2022-001Federal Agency: U.S. Department of LaborU.S. Department of TreasuryU.S. Department of Health and Human ServicesFederal Program: WIOA ClusterCOVID-19-Coronavirus State and Local Fiscal Recovery FundsAging ClusterProjects for Assistance in Transition from Homelessness (PATH)Block Grants for Community Mental Health ServicesAssistance Listing Number: 17.258/17.259/17.278, 21.027, 93.044/93.045/93.053, 93.150, 93.958Pass-through Agency: Maryland Department of Labor, Maryland Department of Health Maryland Department of AgingPass-through Number: P26-BCO-PY22-A, P26-BCO-PY21-A, P06-BCO-FY20-A,P26-BCO-PY21-Y, P16-BCO-PY20-Y, P16-BCO-FY21-D,P16-BCO-PY20-D, P26-BCO-PY21-D, P16-BCO-FY21-DAAA-3-24-004, 2010MDSSC6-00, 2101MDCMC6,2101MDHDC6-00, ST-2505-004, MH184OTH, MH222OTHCompliance Requirement: Reporting: Schedule of Expenditures of Federal AwardsType of Finding: Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200 Section 510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. It must also include the total amount provided to subrecipients from each Federal program. Per Section 502(g), Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA). Errors included:? Under the WIOA Cluster, the County was unable to reconcile the amount reported on the draw downs to the amount reported in the general ledger to ensure expenditures were accurately reported on the SEFA.? The original SEFA underreported the Coronavirus State and Local Fiscal Recovery Funds grant by $1.2 million.? During our testing of payroll in the Aging Cluster, it was noted that 2 of 40 expenditures tested totaling $615 were incorrectly reported on the FY 2022 SEFA. They should have been reported on the FY 2021 SEFA.? Incorrect subrecipients expenditures were reported on the SEFA as follows:o Emergency Rental Assistance Program ? the amount of subrecipient expenditures were incorrectly reported.o Projects for Assistance in Transition from Homelessness (PATH) and Block Grant for Community Mental Health Services ? the subrecipient amount reported on the SEFA exceeded the total expenditures.Cause:Turnover in the grant accountant position resulted in other County staff completing the schedule of expenditures of federal awards, who were not involved in the grant process throughout the year.Effect:Federal expenditures were incorrectly reported on the SEFA , which were subsequently corrected.Questioned Costs:UndeterminedRecommendation:We recommend that the County improve its SEFA compilation process to ensure that program expenditures reported on the County?s SEFA are complete and accurate. Procedures and controls should include a process to identify programs that are new to the County and ensure they are properly reported on the SEFA.We further recommend that County?s Office of Budget and Finance (OBF) work with the County?s agencies and departments to review and update their SEFA review and confirmation procedures to ensure that expenditure information they submit to OBF is accurate, that it includes all programs expended, and ties to detail expenditure transactions in the County?s accounting system. They should also review and enhance procedures and controls to ensure that subrecipient payments are accurately reported.Views of Responsible Officials:See separate Correction Action Plan related to this finding.
Food Commodity Shipments, Disbursements, and Inventory Not Tracked(Utah State Board of Education)Federal Agency: Department of EducationALN Numbers & Titles: 10.569 Emergency Food Assistance Program (Food Commodities)Federal Award Numbers: VariousQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Utah State Board of Education (USBE) does not have procedures to ensure that food commodity shipments, disbursements, and inventory balances, as reported by its subrecipient, are properly tracked, accounted for, and reconcile to federal records. As a result, 123,923 cases of food, with a $52,875 estimated value, could not be accounted for when our audit compared fiscal year 2022 shipment and disbursement records. These discrepancies were subsequently reconciled by USBE, therefore we are not questioning the associated costs.As the prime recipient for the Food Distribution Cluster, USBE is required to ?maintain records to document the receipt, disposal, and inventory of commodities received? (7 CFR 251.10). It is also required to ?establish and maintain effective internal control [procedures]?that provides reasonable assurance that the ? entity is managing [the program] in compliance with?terms and conditions of the federal award? (2 CFR 200.303). Without such procedures, USBE will be unable to accurately track food commodity shipments, and may be liable for untraceable shipments (7 CFR 250.19).Recommendation:We recommend that USBE establish procedures to ensure that food commodity shipments, disbursements, and inventory balances are properly tracked, accounted for, and reconcile to federal records.USBE?s Response:The USBE partially agrees with this finding.
FFATA Award Information Not Submitted for UOVC?s 2020 Award & Inaccurate Information Submitted for 5 of UOVC?s 2019 Subawards(Commission on Criminal and Juvenile Justice)Federal Agency: Department of JusticeAssistance Listing Number and Title: 16.575 Crime Victim AssistanceFederal Award Number: 2019-V2-GX-00632020-V2-GX-0015Questioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AUtah?s Office of Victims of Crime (UOVC) did not submit Federal Funding Accountability and Transparency Act (FFATA) information for 13 awards to 13 subrecipients, all related to the 2020 award. In addition, 5 of the 28 grant awards we reviewed were reported in FSRS but the amounts reported did not agree to the subaward letters, with differences ranging from $34 to $405,000. We reviewed USASpending.gov and noted that no subrecipient award information for the 2020-V2-GX-0015 award had been submitted as of August 22, 2022 (the time of our audit). The following table summarizes the discrepancies for the transactions and subawards tested:(See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires entities to ?establish and maintain effective internal controls [procedures]?that provide reasonable assurance that the ? entity is managing [federal program] in compliance with? terms and conditions of the federal award.? This control does not exist because managers both relied on an external control at the federal level to flag reporting issues and misunderstood reporting deadlines. Lack of FFATA reporting internal controls at UOVC results in noncompliance with grant requirements and reduces the transparency desired by the federal government.Recommendation:We recommend that UOVC implement controls over FFATA reporting and enter final award information rather than preliminary award information to ensure timely submission of accurate information.UOVC?s Response:UOVC Agrees.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Missing/Untimely Submissions and Errors in FFATA Reporting(Department of Workforce Services)Federal Agency: Department of EducationDepartment of TreasuryDepartment of Health and Human ServicesAssistance Listing Number and Title: 84.126 Vocational Rehabilitation21.023 Emergency Rental Assistance Program93.568 Low-Income Home Energy Assistance Program93.575, 93.596 CCDF ClusterFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-006DWS did not have a control implemented to ensure timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. As a result we identified the following errors in our sample of six subawards across the four different programs.? Three subawards were not reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS);? The subaward obligation/action date for two reported subawards was inaccurately reported in FSRS; and? Three subawards were not reported timely in FSRS.These errors and the associated dollar amounts are summarized as follows: (See the Schedule of Findings and Questioned Costs for the table)2 CFR 200.303 requires that ?the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 170 states that DWS ?must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity.? The regulation further states that subaward information should be reported ?no later than the end of the month following the month in which the obligation was made.? First-tier subrecipients and subawards should be reported and submitted on FSRS in a timely manner.Although DWS had designed an internal control over FFATA reporting, the control was not implemented because the COVID-19 pandemic delayed training for newly hired personnel to assist with the internal control. Failure to properly implement internal controls over reporting can lead to inaccurate reporting and noncompliance with Federal regulations.Recommendation:We recommend DWS implement internal controls to ensure accurate and timely FFATA reporting.DWS?s Response:We agree with the finding.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Suspension and Debarment Not Verified Prior to Awarding Contracts(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: $0Pass-through Entity: N/APrior Year Single Audit Report Finding Number: 2021-022We identified 26 of 42 contract agreements sampled (61.9 percent error) where, under GOPB?s oversight, the state agency awarded SLFRF without verifying the entity was not suspended or debarred. These state agencies did not include a suspension and debarment clause in the contract with the entity as required by 2 CFR 200.327 or through a search of the suspension and debarment list on sam.gov: (See the Schedule of Findings and Questioned Costs for the table)2 CFR part 200.303 requires non-federal entities to ?establish and maintain effective internal control?that provides reasonable assurance that the non-federal entity [manages the program] in compliance with?terms and conditions of the federal award.? At the time of the award, GOPB did not provide guidance to these agencies that were inexperienced with federal programs to be aware of the extent that the suspension and debarment requirements were applicable. Although our procedures did not detect noncompliance, failure to properly implement controls and appropriately review each contracted party for suspension and debarment could result in federally suspended or debarred entities receiving federal funds.Recommendation:We recommend GOPB assist agencies to gain an understanding of the suspension and debarment requirements and establish internal controls to ensure compliance with these requirements.GOPB?s Response:GOPB agrees with this finding. In September 2022, GOPB distributed an ARPA Agency Checklist to remind those managing SLFR funds of compliance, monitoring, and reporting requirements, which included the requirement of monitoring for suspension and debarment. This checklist tool was not consistently used. A retroactive check was performed and no entities receiving federal funds had been suspended or debarred.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.